Internal control over financial reporting

3. Refer to your September 29, 2025 response. You say, “We have evaluated the total possible exposure related to this control deficiency and believe the maximum exposure related to the above-mentioned control deficiency is the amounts listed in the noted errors.” Since you misinterpreted the interpretive guidance, please explain in detail how the potential magnitude of the errors that could have resulted from the control deficiency would be limited to the amounts of the actual errors. For example, suppose you had additional transactions of a similar nature during each of the prior periods when the errors occurred, please explain why you believe you would have accounted for those correctly. Otherwise, please revise your response to tell us how big the errors could have been before you identified them. Also, tell us about any compensating controls and whether they were operating at a…

Comment 2 : Please confirm whether the Internal Control Report ( i.e. , the Auditor Report) included in the December 31, 2024 Form N-CEN for the FS Multi-Strategy Alternatives Fund should make reference to financial statements being consolidated [ i.e. , the financial statements for both (i) the FS Multi-Strategy Alternatives Fund and (ii) the FS Alternatives Fund (Cayman), the FS Multi-Strategy Alternatives Fund’s wholly-owned subsidiary. If these FS Multi-Strategy Alternatives Fund financial statements do represent the consolidated financial statements for both the FS Multi-Strategy Alternatives Fund and the FS Alternatives Fund (Cayman), then please also confirm that, going forward, an appropriate note shall be provided in the Internal Control Report to be included in the FS Multi-Strategy Alternatives Fund’s Form N-CEN that discloses that these financial statements represent the…

Comment 2: Please explain why recently amended Form N-CSRs filed September 12, 2022 refer to a “quarter” covered by the report for the disclosure covered by the report under item 11(b). Please use the language provided in N-CSR item 11(b), which refers to the “period” covered by the report, not isolated to a particular quarter, and confirm that, for the series of Forum Funds not referenced in the Registrant’s prior correspondence dated September 20, 2022, that there have been no changes in the Registrant’s internal control over financial reporting during the period.

Comment: It appears the N-CSR for the period 10/31/22 refers to a “quarter” covered by the report for the disclosure related to Form N-CSR Item 11(b). Please utilize the language provided in form N-CSR Item 11(b) which refers to period covered by the report not isolated to a particular quarter and confirm that there have been no such changes in the registrant’s internal control over financial reporting that occurred during the period. This also applies to Item 4(d) of the 302 certification included in exhibit 13(a)(2) of the 10/31/22 NCSR filing. Morgan, Lewis & Bockius llp 1111 Pennsylvania Avenue, NW Washington, DC 20004 +1.202.739.3000 United States +1.202.739.3001 March 23, 2023 Page 2 Item 11(b) from 10/31/22 N-CSR filed by BBH - There were no changes in the Registrant’s internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act) that occurred during…

Comment 2: In Item B.22.a. of Form N-CEN (Net asset value corrections (open-end management investment companies only)), as of August 31, 2022, the Fund indicated “Yes” to the question regarding whether, “[d]uring the reporting period, [there] were any payments made to shareholders or shareholder accounts reprocessed as a result of an error in calculating the Registrant’s net asset value (or net asset value per share).” Please supplementally describe the nature and circumstances of the NAV error, including: (i) any internal control implications; (ii) any mitigation actions to address internal controls implications; and (iii) amount reimbursed. In addition, if amounts have been reimbursed, please explain why the Fund has not disclosed such reimbursements in its financial statements and cite any applicable accounting guidance that would explain was it was not disclosed.

Comment 3: In Item B.22.a. of Form N-CEN (Net asset value corrections (open-end management investment companies only)), as of August 31, 2022, the Fund indicated “Yes” to the question regarding whether, “[d]uring the reporting period, [there] were any payments made to shareholders or shareholder accounts reprocessed as a result of an error in calculating the Registrant’s net asset value (or net asset value per share).” Please supplementally describe the nature and circumstances of the NAV error, including: (i) any internal control implications; any mitigation actions to address internal controls implications; and (iii) amount reimbursed. In addition, if amounts have been reimbursed, please explain why the Fund has not disclosed such reimbursements in its financial statements and cite any applicable accounting guidance that would explain was it was not disclosed.

Comment : On Form N-CEN Item B.22 please describe in correspondence the nature and circumstances of the NAV error for the Janus Henderson International Sustainable Equity ETF, associated internal control implications, and mitigating actions if any.

1. On the Cover Page, we note that you checked the following box: “ Indicate by check mark whether the Registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report.” Non-accelerated filers such as the Company are not required to file such reports. Please correct this in future filings.

2. On Page 13, under the heading “Securities Exchange Act and Sarbanes-Oxley Act Compliance,” the third bullet point states: “ pursuant to Rule 13a-15 of the Exchange Act, our management will be required to prepare a report regarding its assessment of our internal control over financial reporting. This report must be audited by our independent registered public accounting firm…” Non-accelerated filers such as the Company are not required to file such reports. Please remove this bullet point in future filings.

Comment 11: The Registrant's Form N-CSR Item 11(b) disclosure does not appear to match the language in the Form. Please file an amended Form N-CSR to correct and ensure that the certifications are updated to a current date. Registrant's language: b) Internal Controls. There were no significant changes in Registrant’s internal controls of in other factors that could significantly affect these controls subsequent to the date of their evaluation, including any corrective actions with regard to significant deficiencies and material weaknesses. Ms. Christina DiAngelo Fettig Page 5

Comment : The Staff notes that the Internal Control Letters attached to the Registrant’s reports filed on Form N-CENs for the fiscal years ended September 30, 2021 and September 30, 2022 did not identify the city and state in which the letters were issued. Please ensure that the city and state are included in future Internal Control Letters.

Comment : The SEC staff notes that Registrant’s report filed on Form N-CEN for the fiscal year ended September 30, 2022 indicates that five Funds had net asset value (“NAV”) corrections during the period covered by the report. Please describe the nature and circumstances of these errors and the associated internal control implications, mitigating actions and amounts of reimbursements, if any, associated with the NAV corrections. If any amounts were reimbursed to the Funds, please explain why the reimbursements were not disclosed in the Funds’ financial statements.

3. In a related matter, please tell us your consideration of management’s assessment of the effectiveness of ICFR in light of the restatement. If no consideration will be given, please explain why. That is, please explain to us why you believe internal controls over financial reporting continue to be effective in light of the error and why no modifications to the disclosures contained management’s report, including any material changes made to ICFR, are required.

2. You state that management has reviewed your current internal controls over financial reporting and concluded they are effective. You also indicate that during the course of documenting and testing your internal control over financial reporting, you may identify weaknesses and deficiencies in your internal control over financial reporting. Given you have restated the financial statements as a result of errors coupled with the fact that the key performance indicators previously provided were incorrect, please revise these disclosures as appropriate. In this regard, while we acknowledge that you are not yet subject to the requirements of Section 404 of the Sarbanes-Oxley Act of 2002, tell us how management's conclusion regarding your controls is still appropriate, or revise. Further, disclose whether you are now aware of any significant deficiencies or material weaknesses in your…

7. With respect to the TOBAM Emerging Markets Fund, please supplement the information provided by the Trust in the Form N-CEN regarding the material weakness in the Fund’s internal control over financial reporting and its operation with additional information regarding the matter, including the timeline during which the material weakness occurred, whether a net asset value (“NAV”) error occurred, the impact (if any) to shareholders, whether any transactions were reprocessed or if shareholders were otherwise made whole.

Comment : Please revise to include disclosure regarding your exploration program internal controls as required by Item 1305 of Regulation S-K.

1. We note your disclosure that you identified and corrected a presentation error related to funds held on behalf of clients in the Consolidated Statements of Cash Flows. Please address the items below. • Provide us with a full and detailed description of the error, including, but not limited to, a discussion of who identified the error, when, and how, and whether it was the result of any control deficiency. • In your response to the above bullet, ensure you include a thorough discussion and description of the control deficiency to the extent one was identified, the Company’s evaluation of whether it was a control deficiency, significant deficiency, or material weakness, and any remediation plans. To the extent the Company concluded there was not a control deficiency, tell us why. • Provide us with your assessment of materiality supporting your conclusion that it was immaterial. Ensure…

1. We have read your response to comment 3 noting that you have re-assessed your conclusion on the effectiveness of your disclosure controls and procedures and that you believe that they were effective as of December 31, 2021. Based on the number and nature of the deficiencies noted, we continue to consider the omitted disclosures and information required to comply with SK 1300 to be material and do not agree with the conclusion of your re-assessment. Please revise to state that your disclosure controls and procedures were not effective as of December 31, 2021 in your amended Form 20-F.