SECURITIES AND EXCHANGE COMMISSION

Investment Company Act Release No. 35153; 812-15531 

James Alpha Funds Trust d/b/a Easterly Funds Trust and Easterly Investment Partners LLC 

March 12, 2024 

AGENCY: Securities and Exchange Commission (“Commission” or “SEC”).

ACTION: Notice.

Notice of an application under section 6(c) of the Investment Company Act of 1940 (“Act”) for 

an exemption from Section 15(a) of the Act, as well as from certain disclosure requirements in 

Rule 20a-1 under the Act, Item 19(a)(3) of Form N-1A, Items 22(c)(1)(ii), 22(c)(1)(iii), 22(c)(8) 

and 22(c)(9) of Schedule 14A under the Securities Exchange Act of 1934, and Sections 6-

07(2)(a), (b), and (c) of Regulation S-X (“Disclosure Requirements”).

Summary of Application: The requested exemption would permit Applicants to enter into and 

materially amend subadvisory agreements with certain subadvisors without shareholder approval 

and grant relief from the Disclosure Requirements as they relate to fees paid to the subadvisors.

Applicants: James Alpha Funds Trust d/b/a Easterly Funds Trust and Easterly Investment 

Partners LLC.

Filing Dates: The application was filed on December 8, 2023, and amended on February 9, 

2024. 

Hearing or Notification of Hearing: An order granting the requested relief will be issued unless 

the Commission orders a hearing. Interested persons may request a hearing on any application 

by e-mailing the SEC’s Secretary at Secretarys-Office@sec.gov and serving the Applicants with 

a copy of the request by e-mail, if an e-mail address is listed for the relevant Applicant below, or 

personally or by mail, if a physical address is listed for the relevant Applicant below. Hearing 
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requests should be received by the Commission by 5:30 p.m. on April 8, 2024, and should be 

accompanied by proof of service on the Applicants, in the form of an affidavit, or, for lawyers, a 

certificate of service. Pursuant to rule 0-5 under the Act, hearing requests should state the nature 

of the writer’s interest, any facts bearing upon the desirability of a hearing on the matter, the 

reason for the request, and the issues contested. Persons who wish to be notified of a hearing 

may request notification by emailing the Commission’s Secretary. 

ADDRESSES: The Commission: Secretarys-Office@sec.gov. Applicants: Darrell Crate, 

dcrate@easterlyam.com; Matthew DiClemente, Esq., mdiclemente@stradley.com; and Michael 

W. Mundt, Esq., mmundt@stradley.com. 

FOR FURTHER INFORMATION CONTACT: Jill Ehrlich, Senior Counsel, or Lisa Reid 

Ragen, Branch Chief, at (202) 551-6825 (Division of Investment Management, Chief Counsel’s 

Office).

SUPPLEMENTARY INFORMATION: For Applicants’ representations, legal analysis, and 

conditions, please refer to Applicants’ amended application, dated February 9, 2024, which may 

be obtained via the Commission’s website by searching for the file number at the top of this 

document, or for an Applicant using the Company name search field on the SEC’s EDGAR 
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system. The SEC’s EDGAR system may be searched at 

https://www.sec.gov/edgar/searchedgar/legacy/companysearch.html. You may also call the 

SEC’s Public Reference Room at (202) 551-8090.

For the Commission, by the Division of Investment Management, under delegated 

authority.

Sherry R. Haywood,

Assistant Secretary.