Midas Series Trust
2255 Buffalo Road
Rochester, NY 14624
April 6, 2023
VIA EDGAR CORRESPONDENCE
Deborah L. O’Neal
Division of Investment Management, Disclosure Review Office
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Response to Comments on Post-Effective Amendment No. 74 (the “Post-Effective Amendment”) to the Registration Statement of Midas Series Trust (the “Registrant” or “Fund”) (002-98229; 811-04316) |
Dear Ms. O’Neal:
On behalf of the Registrant, set forth below are the comments that you (the “Staff”) provided by email on April 5, 2023 concerning the Fund’s Post-Effective Amendment which was filed with the Securities and Exchange Commission (the “SEC”) on February 27, 2023, and the Registrant’s response thereto.
| 1. | Comment: Given the pivot/flexibility in the fund’s principal investment strategy, consider highlighting the disclosure on page 2 that states, “provided, however, that the Fund’s investment adviser . . . . may invest in any type of equity security (e.g., common and preferred stocks)” with bold or italicized font. |
Response: The Fund will make the requested change.
* * * * *
Should you have any further comments on these matters, or any questions, please contact me at (212) 785-0900, extension 275, or rkamerman@midasfunds.com.
Sincerely,
MIDAS SERIES TRUST
| By: | /s/Russell Kamerman
|
| | Name:
| Russell Kamerman
|
| | Title:
| General Counsel
|
| cc: | Pamela M. Krill, Esq. |
| | Godfrey & Kahn, S.C. |
