0001623632-21-000777.txt : 20210823 0001623632-21-000777.hdr.sgml : 20210823 20210628104932 ACCESSION NUMBER: 0001623632-21-000777 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20210628 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Federated Hermes Adviser Series CENTRAL INDEX KEY: 0001707560 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4000 ERICSSON DRIVE CITY: WARRENDALE STATE: PA ZIP: 15086-7561 BUSINESS PHONE: 1-800-341-7400 MAIL ADDRESS: STREET 1: 4000 ERICSSON DRIVE CITY: WARRENDALE STATE: PA ZIP: 15086-7561 FORMER COMPANY: FORMER CONFORMED NAME: Federated Adviser Series DATE OF NAME CHANGE: 20200616 FORMER COMPANY: FORMER CONFORMED NAME: Federated Hermes Adviser Series DATE OF NAME CHANGE: 20200615 FORMER COMPANY: FORMER CONFORMED NAME: Federated Adviser Series DATE OF NAME CHANGE: 20180820 CORRESP 1 filename1.htm

FEDERATED HERMES ADVISER SERIES

4000 Ericsson Drive
Warrendale, Pennsylvania 15086-7561

June 28, 2021

 

Mark Cowan

U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549-4720

 

RE:

FEDERATED HERMES ADVISER SERIES (the “Registrant”)

Federated Hermes MDT Market Neutral Fund (the “Fund”)

Class A Shares

Institutional Shares

 

1933 Act File No. 333-218374

1940 Act File No. 811-23259

Dear Mr. Cowan:

The Registrant is filing this correspondence to respond to additional comments of the Staff of the Securities and Exchange Commission (“Staff”), provided on June 23 and 24, 2021, regarding its Post-Effective Amendment No. 41 under the Securities Act of 1933 and Amendment No. 42 under the Investment Company Act of 1940 to the Registration Statement of the above-referenced Registrant and Fund filed on April 8, 2021.

The Registrant notes that the Fund is proposed to be the acquiring fund in a proposed reorganization (the “Reorganization”) with Hancock Horizon Quantitative Long/Short Fund (the “Predecessor Fund”)

COMMENT 14. Prospectus - Risk/Return Summary: Performance Bar Chart and Table

 

The Staff reiterates its position that the historical performance of the Predecessor Fund’s Investor Class as reflected in the Fund’s acquiring Class A Shares should be adjusted to reflect the Fund’s Class A Shares sales load.

 

RESPONSE:

The Registrant will make the requested changes. Accordingly, the Registrant withdraws its response to this comment in the Registrant’s second correspondence filed on June 23, 2021.

COMMENT 18. Prospectus – What Do Shares Cost?

The Staff reiterates its comment to delete the following sentence: “The information contained in Appendix B is based on information provided by these financial intermediaries.”

The disclosure cannot disclaim responsibility for the Fund’s sales charge waivers and discounts disclosure. Under the 1940 Act, sales loads are set by funds, not by intermediaries.

RESPONSE:

With respect to the noted sentence, the Registrant respectfully continues to believe that the disclosure in question is, in the Registrant’s view, accurate and not a disclaimer of responsibility. The Registrant, the Fund, and its investment adviser do not establish or determine financial intermediary-specific policies and procedures. These policies and procedures are solely determined by a financial intermediary and the Registrant makes the financial intermediary’s policy, as provided by the intermediary, available to shareholders with Appendix B. Accordingly, the Registrant respectfully declines to make any changes beyond those included in the Registrant’s second correspondence filed on June 23, 2021.

Questions on this letter or requests for additional information may be directed to me at Leslie.Petrone@FederatedHermes.com.

Very truly yours,

 

/s/ Leslie C. Petrone
Leslie C. Petrone
Senior Manager
Federated Hermes, Inc.