SEC Company Response from EATON VANCE SPECIAL INVESTMENT TRUST (CIK 0000031266) — Feb 28, 2020
EATON VANCE SPECIAL INVESTMENT TRUST (CIK 0000031266)
Date: Feb. 28, 2020 · CIK: 0000031266 · Accession: 0000940394-20-000418
AI Filing Summary & Sentiment
File numbers found in text: 811-01545
Letter
VIA EDGAR Re: 485(a) Filing for Eaton Vance Special Investment Trust (the “Registrant”) on behalf of: Parametric 1-to-10 Year Laddered Corporate Bond Fund (the “Fund”) Post-Effective Amendment No. 192 (1933 Act File No. 002-27962) Amendment No. 179 (1940 Act File No. 811-01545) (the “Amendment”)
Dear Ms. Larkin:
This letter responds to the comments you provided telephonically to the undersigned, Deanna Foley and Lindsey Langille on February 14, 2020 with respect to the Amendment. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Amendment. The comments and Registrant’s responses thereto are as follows:
1. Footnote 1 to the fee table for the Fund states that the Fund’s investment adviser and sub-adviser have agreed to reimburse the Fund’s expenses over certain amounts. Please confirm that the Fund’s sub-adviser is participating in the expense reimbursement. In addition, please confirm that the Fund’s Sub-Advisory Agreement and expense reimbursement agreement will be filed as exhibits.
Response: The Registrant confirms that, pursuant to the Fund’s Sub-Advisory Agreement, the sub-adviser and investment adviser bear the amount of any expense reimbursement in proportion to the Fund’s investment advisory fee and sub-advisory fee, respectively. The Fund’s Sub-Advisory Agreement and expense reimbursement agreement will be filed as exhibits to the Fund’s registration statement.
2. Footnote 1 to the fee table for the Fund states that the Fund’s expense reimbursement arrangement will continue through December 31, 2020. The instructions to Item 3 of Form N-1A permit the Fund to reflect expense reimbursement arrangements in the fee table only if such arrangements will reduce Fund operating expenses for no less than one year from the effective date of the Fund’s registration statement. Please either confirm that the Fund’s expense reimbursement arrangement will continue in effect for at least one year following the effective date of the Amendment or remove the referenced footnote and related line items from the expense table.
Response: The Registrant confirms that the Fund’s expense reimbursement arrangements will continue in effect until at least December 31, 2021. Footnote 1 will be updated accordingly.
If you have any questions or comments concerning the foregoing, please contact the undersigned at (617) 672-6170.
Very truly yours,
/s/ Jill R. Damon
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Eaton Vance Management
Two International Place
Boston, MA 02110
(617) 482-8260
www.eatonvance.com
February 28, 2020
VIA EDGAR
Ms. Lisa Larkin
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
485(a) Filing for Eaton Vance Special Investment Trust (the “Registrant”) on behalf of:
Parametric 1-to-10 Year Laddered Corporate Bond Fund (the “Fund”)
Post-Effective Amendment No. 192 (1933 Act File No. 002-27962)
Amendment No. 179 (1940 Act File No. 811-01545) (the “Amendment”)
Dear Ms. Larkin:
This letter responds to the comments you provided telephonically to
the undersigned, Deanna Foley and Lindsey Langille on February 14, 2020 with respect to the Amendment. Capitalized terms not otherwise
defined herein have the meanings ascribed to them in the Amendment. The comments and Registrant’s responses thereto are as
follows:
1.
Footnote 1 to the fee table for the Fund states that
the Fund’s investment adviser and sub-adviser have agreed to reimburse the Fund’s expenses over certain amounts. Please
confirm that the Fund’s sub-adviser is participating in the expense reimbursement. In addition, please confirm that the Fund’s
Sub-Advisory Agreement and expense reimbursement agreement will be filed as exhibits.
Response: The Registrant confirms that,
pursuant to the Fund’s Sub-Advisory Agreement, the sub-adviser and investment adviser bear the amount of any expense reimbursement
in proportion to the Fund’s investment advisory fee and sub-advisory fee, respectively. The Fund’s Sub-Advisory Agreement
and expense reimbursement agreement will be filed as exhibits to the Fund’s registration statement.
2. Footnote 1 to the fee table
for the Fund states that the Fund’s expense reimbursement arrangement will continue through December 31, 2020. The instructions
to Item 3 of Form N-1A permit the Fund to reflect expense reimbursement arrangements in the fee table only if such arrangements
will reduce Fund operating expenses for no less than one year from the effective date of the Fund’s registration statement.
Please either confirm that the Fund’s expense reimbursement arrangement will continue in effect for at least one year following
the effective date of the Amendment or remove the referenced footnote and related line items from the expense table.
Response: The Registrant confirms that
the Fund’s expense reimbursement arrangements will continue in effect until at least December 31, 2021. Footnote 1 will be
updated accordingly.
If you have any questions or comments concerning the foregoing, please
contact the undersigned at (617) 672-6170.
Very truly yours,
/s/ Jill R. Damon
Jill R. Damon, Esq.
Vice President