Disclaimer of responsibility clause samples

Response: The disclosure is accurate as presented and is not a disclaimer of responsibility. Comment 29: The Staff’s understanding was that the last sentence of the third paragraph under Share ClassFeatures in the Choosing a Share Class – Summary of Share ClassFeatures section had been previously revised as follows: “The financial intermediaries that offer their own sales charge reductions or waivers, as described in Appendix A, should, as need be, be consulted to ensure that you receive any such reductions or waivers that may be available to you through the particular financial intermediary. Thus, please consult your financial intermediary for additional information regarding any sales charge reduction and/or waiver described in Appendix A.” Response: Upon subsequent review of the disclosure, additional non-material changes have been made to the disclosure. The current version of disclosure will continue to be used going forward. Comment 30: Please delete disclosure throughout the second paragraph under ClassA and ClassV Shares Front-End Sales Charge Waivers in the Choosing a Share Class – Reductions/Waivers of Sales Charges section that refers to financial intermediaries that have entered into agreements with the Distributor or specify these financial intermediaries. The same comment applies to the first paragraph under ClassT Sales Charge Waivers in the same section. Response: We are continuing to consider the Staff’s comment and evaluating internally its scope within an organization as large as Columbia Threadneedle to ensure that any disclosure changes in this regard are appropriately contemplated. Additionally, please note that ClassT shares are no longer offered by any fund in the complex and, therefore, the second portion of Comment 30 is not applicable to the Fund. Comment 31: Please delete the following disclosure from the Appendix A: Financial Intermediary-Specific Reductions/Waivers of Sales Charges section as well any italicized language stating that the information has been provided by the named financial intermediary. The Fund cannot disclaim responsibility. The Fund is ultimately responsible for whether the sales discounts/waivers are received.

Response: The disclosure is accurate as presented and is not a disclaimer of responsibility. STATEMENT OF ADDITIONAL INFORMATION (SAI) COMMENTS: Comment 32: Please refer to any prior SAI comments given by the Staff. Response: To our knowledge the disclosure in this filing reflects consideration of such prior comments. Comment 33: Please confirm that the date of August1, 2019 is the correct date of the Fund name change as referenced in the Fund Name Change table in the About the Trust section of the SAI. Response: So confirmed. If you have any questions, please contact either me at (212) 850-1703 or Heidi Brommer at (612) 671-2403.

Response: The disclosure is accurate as presented and is not a disclaimer of responsibility. In no way does the Fund, the Investment Manager or the Distributor “establish” or determine financial intermediary-specific shareholder policies; policies applicable to a particular financial intermediary are, in fact, determined by that financial intermediary, and the Registrant makes the intermediary’s policy – as provided by such financial intermediary – available within the registration statement.

Response: The disclosure is accurate as presented and is not a disclaimer of responsibility. Comment 6: Delete disclosure throughout the second paragraph under ClassA and ClassV Shares Front-End Sales Charge Waivers in the Choosing a Share Class – Reductions/Waivers of Sales Charges section that refers to financial intermediaries that have entered into agreements with the Distributor or specify these financial intermediaries. Response: We are continuing to consider the Staff’s comment and evaluating internally its scope within an organization as large as Columbia Threadneedle to ensure that any disclosure changes in this regard are appropriately contemplated. Comment 7: The Staff requests deletion of all disclosure stating that the information has been provided by the named financial intermediary from Appendix A: Financial Intermediary-Specific Reductions/Waivers of Sales Charges section as well any italicized language stating that the information. However, the Fund can add language referring shareholders to the intermediary for help with understanding the waivers. The financial intermediary-specific information below may be provided by, or compiled from or based on information provided by the financial intermediaries noted. The Funds, the Investment Manager and the Distributor do not establish these financial intermediary-specific policies.

With respect to the sentence that states, “The information contained in Annex is based on information provided by these financial intermediaries,” the Registrant respectfully submits that the disclosure in question is, in the Registrant’s view, accurate and not a disclaimer of responsibility. The Registrant, the Funds, and their respective investment advisers 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 Annex C.

With respect to the sentence that states, “The information contained in Appendix B is based on information provided by these financial intermediaries,” the Registrant respectfully submits that the disclosure in question is, in the Registrant’s view, accurate and not a disclaimer of responsibility. The Registrant, the Funds, and their respective investment advisers 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 available the financial intermediary’s policy, as provided.

The Registrant respectfully submits that the disclosure in question is, in the Registrant’s view, accurate and not a disclaimer of responsibility. The Registrant, the Fund or the 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 within Appendix B.