0001162044-10-000216.txt : 20120705 0001162044-10-000216.hdr.sgml : 20120704 20100420134139 ACCESSION NUMBER: 0001162044-10-000216 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20100420 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ARCHER SERIES TRUST CENTRAL INDEX KEY: 0001477491 IRS NUMBER: 000000000 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 9000 KEYSTONE CROSSING STREET 2: SUITE 630 CITY: INDIANAPOLIS STATE: IN ZIP: 46240 BUSINESS PHONE: 3175811300 MAIL ADDRESS: STREET 1: 9000 KEYSTONE CROSSING STREET 2: SUITE 630 CITY: INDIANAPOLIS STATE: IN ZIP: 46240 FORMER COMPANY: FORMER CONFORMED NAME: ARCHER SERIES TRUST DATE OF NAME CHANGE: 20091124 CORRESP 1 filename1.htm Converted by FileMerlin





LAW OFFICE OF C. RICHARD ROPKA, L.L.C.


C. Richard Ropka, LLM (Tax) †

215 Fries Mill Road


Turnersville, New Jersey  08012


†  Admitted to practice in US Supreme Court,

(856) 374-1744                                    


     US District Court & US Tax Court

(1-866) 272-8505 (Fax)



                                                                              


April 20, 2010


Mr. Vincent J. Di Stefano, Senior Counsel

Security and Exchange Commission

450 5th Street

Washington DC 20549


Re:

Archer Investment Series Trust - Form N1-A/A

File Nos. 333-163981 and 811-22356

 


Dear Mr. Di Stefano:


Kindly accept this letter in response to our telephone conversation on April 20, 2010 wherein you have provided comments to our client’s N1-A/A filing submitted on April 14, 2010.  These changes will be implemented in our client’s next amendment as agreed.  


This letter addresses only your comments which we discussed in that telephone conversation.  Accordingly, please find our clients responses below.


FEES AND EXPENSES OF INVESTING IN THE FUND:


Comment & Response:


You have asked that footnote #3 be revised to delete the following phrase. “and do not correlate to the ratio of Expenses to Average Net Assets found in the “Financial Highlights” section of this Prospectus.”  Accordingly, the footnote now reads - “3Acquired Fund Fees and expenses are based on estimated amounts for the current fiscal year.”  The referenced phrase has been deleted.


Comment & Response:


You have asked that the last sentence in the section entitled “Portfolio Turnover” which reads:  “The Fund has not yet begun operations; accordingly, there is no portfolio turnover rate available at this time.” be deleted. The referenced phrase has been deleted.

  

Thank you for your kind attention to this matter.  


Very truly yours,


/s/ C. Richard Ropka, Esq.


C. Richard Ropka, Esq.

CRR/ks