0001145549-23-005952.txt : 20230209 0001145549-23-005952.hdr.sgml : 20230209 20230209164252 ACCESSION NUMBER: 0001145549-23-005952 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 3 CONFORMED PERIOD OF REPORT: 20221130 FILED AS OF DATE: 20230209 DATE AS OF CHANGE: 20230209 EFFECTIVENESS DATE: 20230209 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Investment Managers Series Trust CENTRAL INDEX KEY: 0001318342 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: N-CEN SEC ACT: 1940 Act SEC FILE NUMBER: 811-21719 FILM NUMBER: 23606903 BUSINESS ADDRESS: STREET 1: 235 WEST GALENA STREET CITY: MILWAUKEE STATE: WI ZIP: 53212 BUSINESS PHONE: 626-914-4141 MAIL ADDRESS: STREET 1: 235 WEST GALENA STREET CITY: MILWAUKEE STATE: WI ZIP: 53212 FORMER COMPANY: FORMER CONFORMED NAME: Claymore Trust DATE OF NAME CHANGE: 20050603 FORMER COMPANY: FORMER CONFORMED NAME: Claymore Equity Trust DATE OF NAME CHANGE: 20050218 0001318342 S000011379 Zacks All-Cap Core Fund C000031519 Class C CZOCX C000031520 Institutional Class CZOVX 0001318342 S000032900 Zacks Small-Cap Core Fund C000101542 Investor Class ZSCCX C000138525 Institutional Class ZSCIX 0001318342 S000039554 Riverbridge Growth Fund C000121983 Institutional Class RIVBX C000121984 Investor Class RIVRX 0001318342 S000044038 Zacks Dividend Fund C000136682 Investor Class ZDIVX C000177134 Institutional Class Shares ZDIIX N-CEN 1 primary_doc.xml X0404 N-CEN LIVE 0001318342 XXXXXXXX true false false N-1A S000039554 C000121983 C000121984 S000032900 true S000044038 true S000011379 true INVESTMENT MANAGERS SERIES TRUST 811-21719 0001318342 549300ESWU4ZNAH5Y054 235 WEST GALENA STREET MILWAUKEE 532123948 US-WI US 4142992000 UMB FUND SERVICES, INC. 235 WEST GALENA STREET MILWAUKEE 53212 4142992000 TRANSFER AGENT, FUND ACCOUNTANT AND CO-ADMINISTRATOR MUTUAL FUND ADMINISTRATION, LLC 2220 E. ROUTE 66, SUITE 226 GLENDORA 91740 6269144141 CO-ADMINISTRATOR UMB BANK, N.A. 928 GRAND BOULEVARD, 5TH FLOOR KANSAS CITY 64106 8168605683 CUSTODIAN ZACKS INVESTMENT MANAGEMENT, INC. 227 W. MONROE, SUITE 4350 CHICAGO 60606 8886002783 ADVISER RIVERBRIDGE PARTNERS, LLC 1200 IDS CENTER 80 SOUTH EIGHTH STREET MINNEAPOLIS 55402 6129046200 ADVISER IMST DISTRIBUTORS, LLC THREE CANAL PLAZA, SUITE 100 PORTLAND 04101 8662516920 DISTRIBUTOR N N N-1A 54 Y JAMES E. ROSS N/A N CHARLES H. MILLER N/A N ASHLEY TOOMEY RABUN N/A N WILLIAM H. YOUNG N/A N MAUREEN QUILL 001421521 Y MARTIN W. DZIURA N/A 309 WOODRIDGE LANE MEDIA 19063 XXXXXX N N N N N N N IMST DISTRIBUTORS, LLC 8-66389 000130745 N/A N N TAIT, WELLER & BAKER LLP 00445 N/A N N N N N N N Riverbridge Growth Fund S000039554 549300H3LBKH84JPG461 N 2 0 0 N/A N N N N N/A N/A N/A Rule 32a-4 (17 CFR 270.32a-4) Y Y Y N Riverbridge Partners, LLC 801-57432 000108074 N/A N UMB FUND SERVICES, INC. 084-05792 N/A Y N N INTERCONTINENTAL EXCHANGE, INC. 5493000F4ZO33MV32P92 N N UMB BANK, NATIONAL ASSOCIATION VNOO6EITDJ2YUEBMSZ83 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N UMB FUND SERVICES, INC. 084-05792 SEC File Number Y N N MUTUAL FUND ADMINISTRATION, LLC N/A N/A Y N UMB FUND SERVICES, INC. 084-05792 SEC File Number Y N N WILLIAM BLAIR 8-2698 000001252 549300J0P7XYE8BMZ775 10915.000000000000 J.P. MORGAN SECURITIES LLC 8-35008 000000079 ZBUT11V806EZRVTWT807 8270.000000000000 JEFFERIES & CO., INC 8-15074 000002347 58PU97L1C0WSRCWADL48 7497.000000000000 WELLS FARGO 8-37180 000019616 88KRVSOEKUGQZJ3DKW55 5769.000000000000 STEPHENS, INC. 8-1927 000003496 213800LH6T9XDYZCA534 1232.000000000000 ALLIANCE BERNSTEIN 8-30851 000014549 0JK55UGWSWNF3X7KLQ85 998.000000000000 34681.000000000000 0.000000000000 Y 233769793.000000000000 N N N N Zacks Small-Cap Core Fund S000032900 549300W4JEUN5NKSWH67 N 2 0 0 N/A N N Y N N Mitsubishi UFJ Trust and Banking Corporation JBONEPAGQXF4QP29B387 N N Revenue sharing split 89973.000000000000 990.000000000000 Rule 32a-4 (17 CFR 270.32a-4) Y Y Y N Zacks Investment Management, Inc 801-40592 000110897 N/A N UMB FUND SERVICES, INC. 084-05792 N/A Y N N INTERCONTINENTAL EXCHANGE, INC. 5493000F4ZO33MV32P92 N N UMB BANK, NATIONAL ASSOCIATION VNOO6EITDJ2YUEBMSZ83 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N UMB FUND SERVICES, INC. 084-05792 SEC File Number Y N N MUTUAL FUND ADMINISTRATION, LLC N/A N/A Y N UMB FUND SERVICES, INC. 084-05792 SEC File Number Y N N LBMZ SECURITIES, INC. 8-23266 000007874 5493007YID7U5577RI19 0.000000000000 VIRTU FINANCIAL 8-68015 000148390 54930088MP91YZQJT494 23579.000000000000 JONESTRADING INSTITUTIONAL SERVICES LLC 8-26089 000006888 2138008JJ5PA8H5UIL69 6317.000000000000 ITG INC. 8-44218 000029299 549300S41SMIODVIT266 2853.000000000000 PIPER JAFFRAY & CO. 8-15204 000000665 N/A 2253.000000000000 WEEDEN & CO.L.P. 8-37267 000016835 549300OYBLKSN8M8EW67 229.000000000000 35231.000000000000 JONESTRADING INSTITUTIONAL SERVICES LLC 8-26089 000006888 2138008JJ5PA8H5UIL69 431539.000000000000 VIRTU FINANCIAL 8-68015 000148390 54930088MP91YZQJT494 32355.000000000000 463894.000000000000 N 43621780.000000000000 N N N N Zacks Dividend Fund S000044038 549300C5DLVDVTIG4M13 N 2 0 0 N/A N N Y N N MITSUBISHI UFJ TRUST AND BANKING CORPORATION JBONEPAGQXF4QP29B387 N N Revenue sharing split 324147.000000000000 12.000000000000 Rule 32a-4 (17 CFR 270.32a-4) Y Y Y N Zacks Investment Management, Inc 801-40592 000110897 N/A N UMB FUND SERVICES, INC. 084-05792 N/A Y N N INTERCONTINENTAL EXCHANGE, INC. 5493000F4ZO33MV32P92 N N UMB BANK, NATIONAL ASSOCIATION VNOO6EITDJ2YUEBMSZ83 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N UMB FUND SERVICES, INC. 084-05792 SEC File Number Y N N UMB FUND SERVICES, INC. 084-05792 SEC File Number Y N MUTUAL FUND ADMINISTRATION, LLC N/A N/A Y N N LBMZ SECURITIES, INC. 8-23266 000007874 5493007YID7U5577RI19 0.000000000000 VIRTU FINANCIAL 8-68015 000148390 54930088MP91YZQJT494 13475.000000000000 13475.000000000000 0.000000000000 N 172190736.000000000000 N N N N Zacks All-Cap Core Fund S000011379 549300YU6SQPZHRXBV81 N 1 0 0 N/A N N Y N N Mitsubishi UFJ Trust and Banking Corporation JBONEPAGQXF4QP29B387 N N Revenue sharing split 63992.000000000000 N/A Rule 32a-4 (17 CFR 270.32a-4) Y Y Y N Zacks Investment Management, Inc 801-40592 000110897 N/A N UMB FUND SERVICES, INC. 084-05792 N/A Y N N INTERCONTINENTAL EXCHANGE, INC. 5493000F4ZO33MV32P92 N N UMB BANK, NATIONAL ASSOCIATION VNOO6EITDJ2YUEBMSZ83 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N UMB FUND SERVICES, INC. 084-05792 SEC File Number Y N N UMB FUND SERVICES, INC. 084-05792 SEC File Number Y N MUTUAL FUND ADMINISTRATION, LLC N/A N/A Y N N LBMZ SECURITIES, INC. 8-23266 000007874 5493007YID7U5577RI19 0.000000000000 VIRTU FINANCIAL 8-68015 000148390 54930088MP91YZQJT494 3309.000000000000 3309.000000000000 VIRTU FINANCIAL 8-68015 000148390 54930088MP91YZQJT494 715.000000000000 715.000000000000 N 59464053.000000000000 N N N N true INTERNAL CONTROL RPT 2 riverbridgencen2022.txt RIVERBRIDGE 11.30.22 NCEN LETTER REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Shareholders and Board of Trustees of Investment Managers Series Trust Glendora, California 91740 In planning and performing our audit of the financial statements of Riverbridge Growth Fund (the "Fund"), a series of Investment Managers Series Trust, as of and for the year ended November 30, 2022, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered their internal control over financial reporting, including control activities for safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Fund's internal control over financial reporting. Accordingly, we express no such opinion. The management of the Fund is responsible for establishing and maintaining effective internal control over financial reporting. In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls. A company's internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company's internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a company's assets that could have a material effect on the financial statements. Because of inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate. A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the company's annual or interim financial statements will not be prevented or detected on a timely basis. Our consideration of the Fund's internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the Public Company Accounting Oversight Board (United States). However, we noted no deficiencies in the Fund's internal control over financial reporting and its operation, including controls for safeguarding securities, which we consider to be material weaknesses, as defined above, as of November 30, 2022. This report is intended solely for the information and use of management, Shareholders and Board of Trustees of Investment Managers Series Trust and the Securities and Exchange Commission, and is not intended to be and should not be used by anyone other than these specified parties. /s/TAIT, WELLER & BAKER LLP Philadelphia, Pennsylvania January 27, 2023 To the Shareholders and Board of Trustees of Investment Managers Series Trust Page Two INTERNAL CONTROL RPT 3 zackncen2022.txt ZACKS INTERNAL CONTROL LETTER REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Shareholders and Board of Trustees of Investment Managers Series Trust Glendora, California 91740 In planning and performing our audit of the financial statements of Zacks All-Cap Core Fund, Zacks Small-Cap Core Fund, and Zacks Dividend Fund (the "Funds"), each a series of Investment Managers Series Trust, for the year ended November 30, 2022, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered their internal control over financial reporting, including control activities for safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Funds' internal control over financial reporting. Accordingly, we express no such opinion. The management of the Funds is responsible for establishing and maintaining effective internal control over financial reporting. In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls. A company's internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company's internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a company's assets that could have a material effect on the financial statements. Because of inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate. A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the company's annual or interim financial statements will not be prevented or detected on a timely basis. Our consideration of the Funds' internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the Public Company Accounting Oversight Board (United States). However, we noted no deficiencies in the Funds' internal control over financial reporting and its operation, including controls for safeguarding securities, which we consider to be material weaknesses, as defined above, as of November 30, 2022. This report is intended solely for the information and use of management, Shareholders and Board of Trustees of Investment Managers Series Trust and the Securities and Exchange Commission, and is not intended to be and should not be used by anyone other than these specified parties. /s/TAIT, WELLER & BAKER LLP Philadelphia, Pennsylvania January 27, 2023 To the Shareholders and Board of Trustees of Investment Managers Series Trust Page Two