What changed in this filing

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Item 1B. Unresolved Staff Comments

2025-02-28 compared with 2024-02-29 · 31 added, 29 removed, 7 unchanged (90% of the section changed)

2 unchanged sentences

Cybersecurity

The Trust, through its service providers,

has processes in place to assess, identify and manage material risks from cybersecurity threats.

The Trust’s business is

dependent on the communications and information systems of the Trustee, the Sponsor, the Custodian and other third-party service

The Trustee is responsible for day-to-day administration of the Trust and has implemented a cybersecurity program that

applies to the Trustee and its business, including the administration of the Trust.

Cybersecurity Program Overview

has instituted a cybersecurity program designed to identify, assess and mitigate cyber risks applicable to the administration by the Trustee of the Trust.

risk management program involves risk assessments, implementation of security measures and ongoing monitoring of systems and networks,

including networks on which the Trust relies.

The Trustee actively monitors the current threat landscape to seek to identify material

risks arising from new and evolving cybersecurity threats, including material risks faced by the Trust.

relies on the Trustee, the Sponsor and the Custodian to engage external experts, including cybersecurity assessors, risk

management and information technology professionals, attorneys, consultants and auditors to evaluate cybersecurity measures

and risk management processes, including those applicable to the Trust.

Board Oversight of Cybersecurity Risks

The Trust has no board of trustees and

is administered by the Trustee pursuant to the Trust Agreement.

Accordingly, the Trust relies on the Trustee, the Sponsor and the

Custodian for oversight of cybersecurity risks applicable to the Trust.

Management’s Role in Cybersecurity Risk

has no officers or employees and is administered by the Trustee pursuant to the Trust Agreement.

Trust, through its service providers, has processes in place to assess, identify and manage material risks from cybersecurity

The Trust’s business is dependent on the communications and information systems of the Trustee, the Sponsor, the

Custodian and other third-party service providers.

The Trustee is responsible for day-to-day administration of the Trust and has

implemented a cybersecurity program that applies to the Trustee and its business, including the administration of the Trust.

Cybersecurity

Program Overview

Trustee has instituted a cybersecurity program designed to identify, assess and mitigate cyber risks applicable to the administration

by the Trustee of the Trust.

The cyber risk management program involves risk assessments, implementation of security measures

and ongoing monitoring of systems and networks, including networks on which the Trust relies.

The Trustee actively monitors the

current threat landscape to seek to identify material risks arising from new and evolving cybersecurity threats, including material

risks faced by the Trust.

Trust relies on the Trustee, the Sponsor and the Custodian to engage external experts, including cybersecurity assessors, risk

management and information technology professionals, attorneys, consultants and auditors to evaluate cybersecurity measures and

risk management processes, including those applicable to the Trust.

Oversight of Cybersecurity Risks

Trust has no board of trustees and is administered by the Trustee pursuant to the Trust Agreement.

Accordingly, the Trust relies

on the Trustee, the Sponsor and the Custodian for management of cybersecurity risks applicable to the Trust .

on the Trustee, the Sponsor and the Custodian for oversight of cybersecurity risks applicable to the Trust.

Role in Cybersecurity Risk Management

Trust has no officers or employees and is administered by the Trustee pursuant to the Trust Agreement.

Accordingly, the Trust

relies on the Trustee, the Sponsor and the Custodian for management of cybersecurity risks applicable to the

of Cybersecurity Risk

potential impact of risks from cybersecurity threats to the Trust are assessed by the Trustee, the Sponsor, the Custodian and

third-party service providers on an ongoing basis, and how such risks could materially affect the Trust’s objective, operational

results and financial condition are regularly evaluated.

During the reporting period, the Trustee has not identified any risks

from cybersecurity threats, including as a result of previous cybersecurity incidents, that the Trustee believes have materially

affected, or are reasonably likely to materially affect, the Trust, including its objective, operational results and financial

potential impact of risks from cybersecurity threats to the Trust are assessed by the Trustee, the Sponsor, the Custodian

and third- party service providers on an ongoing basis, and how such risks could materially affect the Trust’s

objective, operational results and financial condition are regularly evaluated.

During the reporting period, the Trustee has

not identified any risks from cybersecurity threats, including as a result of previous cybersecurity incidents, that the

Trustee believes have materially affected, or are reasonably likely to materially affect, the Trust, including its objective,

operational results and financial condition.

Legal Proceedings

1 unchanged sentence

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1B. Unresolved Staff Comments