Correspondence 0001398344-23-020017 from IMPAX FUNDS SERIES TRUST I (CIK 0000076721)
IMPAX FUNDS SERIES TRUST I (CIK 0000076721)
Date: Nov. 1, 2023 · CIK: 0000076721 · Accession: 0001398344-23-020017
AI Filing Summary & Sentiment
File numbers found in text: 811-02064
Letter
Division of Investment Management 100 F Street, NE Washington, DC 20549 Attention: Kimberly Browning Re: Impax Funds Series Trust I (File Nos. 002-38679, 811-02064) (the “Registrant”)
Dear Ms. Browning:
We are writing to respond to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) that you provided by telephone on October 10, 2023 in connection with Post-Effective Amendment No. 103, filed with the Commission on August 25, 2023 pursuant to Rule 485(a) under the Securities Act of 1933, as amended (the “Securities Act”), regarding Impax Global Social Leaders Fund (the “Fund”). The Staff’s comments are summarized below, and each is followed by our response. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the prospectus.
GENERAL COMMENTS
1. Comment. The Staff notes that there is missing or bracketed information in the registration statement. Please include all such information in the Registrant’s 485(b) filing.
Response. The Registrant confirms that all missing or bracketed information will be updated in the Registrant’s 485(b) filing.
2. Comment. The Staff requests that, at least five business days prior to the date of effectiveness of the Registrant’s 485(b) filing, the following information be submitted via EDGAR correspondence: (i) annual fund operating expenses and (ii) expense example.
Response. The Registrant notes that the requested information has been attached hereto as Appendix A.
3. Comment. Whenever a comment is made in one location, it should be considered applicable to similar disclosure elsewhere in the registration statement.
Response. The Registrant acknowledges the comment.
PROSPECTUS
1. Comment. Footnote 1 to the Annual Fund Operating Expenses table states as follows: “Other expenses are based on annualized estimated amounts for the first fiscal year” (emphasis added). Please explain why estimated amounts are annualized.
Response. In response to the Staff’s comment, the italicized term in Footnote 1 to the Annual Fund Operating Expenses table has been deleted and the word “full” inserted before “fiscal year.”
2. Comment. Please confirm supplementally that the reimbursement arrangement referenced in footnote 3 to the Annual Fund Operating Expenses table, if memorialized in a written agreement separate from the prospectus, will be filed with the registration statement. In addition, if the Fund’s investment adviser has the ability to recoup expenses that have previously been reimbursed, please disclose the terms of such recoupment.
Response. The Registrant notes that the Fund’s reimbursement arrangement is not memorialized in a written agreement separate from the prospectus. The Registrant confirms that no reimbursed expenses may be recouped.
3. Comment. The Fund’s principal investment strategy does not clearly define “social leaders.” With respect to the Fund’s name and in accordance with Rule 35d-1 under the Investment Company Act of 1940, as amended (the “1940 Act”):
a. Comment. Please revise the Fund’s investment policy to state that the Fund will invest at least 80% of its net assets (plus any borrowings for investment purposes) in companies that are “social leaders.”
Response. The requested change has been made, as follows:
“Under normal market conditions, the Fund invests at least 80% of its net assets (plus any borrowings for investment purposes) in equity securities of companies that whose products or services the Fund’s Sub-Adviser has determined are ‘social leaders.’”
b. Comment. Please define the term “social leaders” for purposes of the Fund’s 80% policy. Please also provide a source for this definition (e.g., proprietary data, third party data, etc.).
Response. The Registrant has revised the third paragraph in the Principal Investment Strategies section to clarify the definition of “social leaders” and better describe how the Sub-Adviser’s proprietary research supports the investment process, as follows:
“Under normal market conditions, the Fund invests at least 80% of its net assets (plus any borrowings for investment purposes) in equity securities of companies that the Fund’s Sub-Adviser has determined are ‘social leaders.’ To identify social leaders, the Fund’s Sub-Adviser identifies a universe of companies that it has determined (1) derive significant revenues (i.e., at least 20% of revenues) from “social markets,” meaning products or services that address societal challenges, including meeting basic needs, such as food, water, and shelter, or essential services, such as transportation and utilities; broadening economic participation by enabling access to education, jobs, financial services and/or digital services; or improving quality of life through accessible and affordable health care and wellness; and (2) also demonstrate positive behaviors through policies and programs that foster diverse, inclusive and equitable workplace cultures. From this universe, the Fund’s Sub-Adviser selects portfolio companies for the Fund that it determines to be social leaders on a company-by-company basis primarily through the use of fundamental financial analysis, which includes an analysis of ESG factors that the Fund’s Sub-Adviser has determined are financially material. The Fund is not constrained by any particular investment style, and may therefore invest in “growth” stocks, “value” stocks or a combination of both. Additionally, it may buy stocks in any sector or industry, and it is not limited to investing in securities of a specific market capitalization.
Please also see the response to Comment 7 below.
c. Comment. Please disclose the criteria used to meet the Fund’s 80% policy.
Response. Please see the response to Comment 3(b) above.
d. Comment. Please clarify what is meant by “underlying revenue” in the following disclosure: “This taxonomy defines the investable universe for this Fund by identifying businesses that derive at least 20% of their underlying revenue from products and/or services to improve quality of life, broaden economic participation, and meet basic needs” (emphasis added). Please also clarify whether this 20% test is a component of the “social leaders” definition.
Response. In response to the Staff’s comment, the italicized phrase has been replaced with “derive significant revenues (i.e., at least 20% of revenues) from social markets.” Please also see the response to Comment 3(b) above.
4. Comment. Please explain how environmental, social and governance (“ESG”) is defined and the specific ESG factors that the Fund focuses on.
Response. The Registrant believes that its current disclosure adequately describes the specific factors on which the Fund focuses.
5. Comment. Please clarify the investment process used to determine whether a company is a “social leaders” company.” For example, please reconcile the following disclosures to clarify what is meant by a “sustainable investing” approach, “integrating [ESG] analysis and ratings” into portfolio construction and the “use of fundamental analysis, including ESG analysis:”
“The Global Social Leaders Fund follows a sustainable investing approach, investing in companies that the Sub-Adviser believes are well positioned to benefit from the transition to a more sustainable global economy, integrating environmental, social and governance (“ESG”) analysis and ratings into portfolio construction and managing the portfolio within certain risk parameters relative to the Fund’s benchmark universe of MSCI ACWI Index companies” (emphasis added).
“The Fund’s Sub-Adviser selects equity securities on a company-by-company basis primarily through the use of fundamental analysis, including ESG analysis” (emphasis added).
Response. Please see the response to Comment 3(b) above, the disclosure which immediately follows the first paragraph of the referenced disclosure in this comment.
6. Comment. Please disclose (i) whether ESG criteria are applied to every investment or to only some investments made by the Fund, and (ii) whether ESG is the exclusive factor or one of several factors considered by the Fund.
Response. The ESG criteria are applied to each holding in the Fund’s portfolio, except to the extent the Fund “may invest in exchange traded funds (ETFs), credit default swaps on indices, swap contracts or other instruments for cash management or hedging purposes, or to gain temporary market exposures,” as disclosed in the Environmental, Social and Governance (ESG) Criteria section in Item 9. As noted in the response to Comment 3(b) above, the Sub-Adviser also considers fundamental factors in selecting investments for the Fund.
7. Comment. If the Fund relies on a third-party ESG data, scoring or ratings service provider, please identify the third-party service provider or, if there are multiple providers, please identify the primary third-party service provider. Please also summarize the third-party service provider’s methodology and criteria used to generate sustainability data, scores or ratings.
Response. The Fund’s Sub-Adviser makes its own assessment of whether a company is well positioned to benefit from the transition to a more sustainable economy based on data provided by the company itself or by third-party data providers. The Registrant has reviewed the Fund’s current disclosure and believes that it meets the requirements in Item 4(a) of Form N-1A. Accordingly, the Registrant declines to make the requested change.
8. Comment. If the Fund does not rely on a third-party ESG data, scoring or ratings service provider, please briefly disclose how proprietary data sources used by the Fund’s sub-adviser are integrated into the Fund’s investment process to determine companies that are “social leaders.” Please also disclose any risks associated with the use of such proprietary data sources.
Response. Please see the response to Comment 7 above. Also, in response to the Staff’s comment, the Registrant has revised Management Risk in the Principal Risks section, as follows:
“Management Risk The Fund is actively managed. The investment techniques and decisions of the investment adviser and the Fund’s portfolio manager(s), including the investment adviser’s assessment of a company’s ESG profile when selecting investments for the Fund, may not produce the desired results and may adversely impact the Fund’s performance, including relative to other funds that do not consider ESG factors or come to different conclusions regarding such factors. Further, in evaluating a company, the Adviser is often dependent upon information and data obtained from the company itself or from third-party data providers that may be incomplete or inaccurate, which could cause the investment adviser or the Fund’s portfolio manager(s) to incorrectly assess a company’s ESG profile.”
9. Comment. Please clarify what is meant by “managing the portfolio within certain risk parameters” in the following disclosure: “The Global Social Leaders Fund follows a sustainable investing approach, investing in companies that the Sub-Adviser believes are well positioned to benefit from the transition to a more sustainable global economy, integrating environmental, social and governance (“ESG”) analysis and ratings into portfolio construction and managing the portfolio within certain risk parameters relative to the Fund’s benchmark universe of MSCI ACWI Index companies” (emphasis added).
Response. The Registrant believes that the referenced disclosure will be sufficiently understood by a reasonable investor. In response to the Staff’s comment, however, the Registrant has revised the referenced disclosure to add the following parenthetical following the phrase “certain risk parameters:” “(e.g., sector and regional exposure).”
10. Comment. The following disclosure suggests that the Fund’s Sub-Adviser determines whether a particular company addresses societal challenges: “Under normal market conditions, the Fund invests at least 80% of its net assets (plus any borrowings for investment purposes) in companies whose products or services the Fund’s Sub-Adviser has determined address societal challenges…” (emphasis added). In the Staff’s view, it is not sufficient to rely on the adviser’s or sub-adviser’s judgment in making such a determination. Please disclose the factors considered, and the criteria used, to determine what types of companies address societal challenges (e.g., a screen, factors used by a screen or an index).
Response. The Registrant respectfully submits that the Sub-Adviser’s determination of whether a company is or is not a “social leader” is a partially subjective determination. As disclosed in Item 9, the companies in which the Fund may invest do not necessarily meet exemplary standards in all aspects of sustainability or ESG performance because no company is perfect – all company ESG profiles have strengths and weaknesses just as all investment decisions involve assessments of opportunities and risks. Accordingly, the Registrant believes that its investment process, as currently disclosed, adequately describes the criteria used to determine what companies are “social leaders,” and satisfies the requirements of Items 4 and 9 of Form N-1A.
11. Comment. Given that the term “global” is used in the Fund’s name, please expressly describe how the Fund will invest its assets in investments that are tied economically to a number of countries throughout the world. See Investment Co. Act Rel. No. 24828, at n. 42 (Jan. 17, 2001).
Response. In response to your comment, the Fund’s Principal Investment Strategies section has been revised, as follows:
“Under normal market conditions, the Fund will invest primarily in equity securities (such as common stocks, preferred stocks and securities convertible into common and preferred stocks) of companies located around the world, including at least 40% of its net assets in securities of non-US issuers companies organized or located outside the United States or doing a substantial amount of business outside the United States, including those located in emerging markets.”
12. Comment. Given that the term “global” is used in the Fund’s name, please consider describing the Fund’s policy for how it will invest its assets in investments that are tied economically to a number of countries throughout the world in unfavorable market conditions. For example, instead of at least 40% of its net assets, will the Fund invest at least 30% of its net assets in securities of non-US issuers in unfavorable market conditions? If the Fund does not have such a policy, please note supplementally.
Response. The Registrant does not currently have such a policy.
13. Comment. With respect to the following disclosure, please consider deleting the phrase “such as,” as this phrase suggests that the Fund has not summarized the totality of its principal investment strategies and associated investment instruments: “Under normal market conditions, the Fund will invest primarily in equity securities (such as common stocks, preferred stocks and securities convertible into common and preferred stocks) of companies located around the world…” (emphasis added).
Response. The Registrant believes that the referenced phrase helps clarify the types of equity securities in which the Fund will invest. Accordingly, the Registrant respectfully declines to make the requested change.
14. Comment. Please confirm supplementally that all principal investment strategies and principal risks of the Fund are summarized in Item 4, with more detailed disclosure in Item 9.
Response. The Registrant so
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CORRESP
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filename1.htm
ROPES & GRAY LLP
THREE EMBARCADERO CENTER
SAN FRANCISCO, CA 94111-4006
WWW.ROPESGRAY.COM
Jimena Acuña Smith
T +1 415 315 2306
jimena.smith@ropesgray.com
November 1, 2023
BY EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549
Attention: Kimberly Browning
Re: Impax Funds Series Trust I (File Nos. 002-38679, 811-02064) (the “Registrant”)
Dear Ms. Browning:
We are writing to respond to the comments of the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) that you provided by telephone on October 10, 2023 in
connection with Post-Effective Amendment No. 103, filed with the Commission on August 25, 2023 pursuant to Rule 485(a) under the Securities
Act of 1933, as amended (the “Securities Act”), regarding Impax Global Social Leaders Fund (the “Fund”).
The Staff’s comments are summarized below, and each is followed by our response. Capitalized terms not otherwise defined herein
have the meanings ascribed to them in the prospectus.
GENERAL COMMENTS
1. Comment. The Staff notes that there is missing or bracketed information in the registration statement. Please include all such
information in the Registrant’s 485(b) filing.
Response. The Registrant confirms that all missing
or bracketed information will be updated in the Registrant’s 485(b) filing.
2. Comment. The Staff requests that, at least five business days prior to the date of effectiveness of the Registrant’s
485(b) filing, the following information be submitted via EDGAR correspondence: (i) annual fund operating expenses and (ii) expense example.
1
Response. The Registrant notes that the requested
information has been attached hereto as Appendix A.
3. Comment. Whenever a comment is made in one location, it should be considered applicable to similar disclosure elsewhere in
the registration statement.
Response. The Registrant acknowledges the comment.
PROSPECTUS
1. Comment. Footnote 1 to the Annual Fund Operating Expenses table states as follows: “Other expenses are based on annualized
estimated amounts for the first fiscal year” (emphasis added). Please explain why estimated amounts are annualized.
Response. In response to the Staff’s comment,
the italicized term in Footnote 1 to the Annual Fund Operating Expenses table has been deleted and the word “full” inserted
before “fiscal year.”
2. Comment. Please confirm supplementally that the reimbursement arrangement referenced in footnote 3 to the Annual Fund Operating
Expenses table, if memorialized in a written agreement separate from the prospectus, will be filed with the registration statement. In
addition, if the Fund’s investment adviser has the ability to recoup expenses that have previously been reimbursed, please disclose
the terms of such recoupment.
Response. The Registrant notes that the Fund’s
reimbursement arrangement is not memorialized in a written agreement separate from the prospectus. The Registrant confirms that no reimbursed
expenses may be recouped.
3. Comment. The Fund’s principal investment strategy does not clearly define “social leaders.” With respect
to the Fund’s name and in accordance with Rule 35d-1 under the Investment Company Act of 1940, as amended (the “1940 Act”):
a. Comment. Please revise the Fund’s investment policy to state that the Fund will invest at least 80% of its net assets
(plus any borrowings for investment purposes) in companies that are “social leaders.”
Response. The requested change
has been made, as follows:
“Under normal market conditions, the Fund invests at least
80% of its net assets (plus any borrowings for investment purposes) in equity securities of companies that whose
products or services the Fund’s Sub-Adviser has determined are ‘social leaders.’”
b. Comment. Please define the term “social leaders” for purposes of the Fund’s 80% policy. Please also provide
a source for this definition (e.g., proprietary data, third party data, etc.).
2
Response. The Registrant has revised the third paragraph
in the Principal Investment Strategies section to clarify the definition of “social leaders” and better describe how the Sub-Adviser’s
proprietary research supports the investment process, as follows:
“Under normal market conditions, the Fund invests at least
80% of its net assets (plus any borrowings for investment purposes) in equity securities of companies that the Fund’s Sub-Adviser
has determined are ‘social leaders.’ To identify social leaders, the Fund’s Sub-Adviser identifies a universe of
companies that it has determined (1) derive significant revenues (i.e., at least 20% of revenues) from “social markets,” meaning
products or services that address societal challenges, including meeting basic needs, such as food, water, and shelter, or essential services,
such as transportation and utilities; broadening economic participation by enabling access to education, jobs, financial services and/or
digital services; or improving quality of life through accessible and affordable health care and wellness; and (2) also demonstrate positive
behaviors through policies and programs that foster diverse, inclusive and equitable workplace cultures. From this universe, the Fund’s
Sub-Adviser selects portfolio companies for the Fund that it determines to be social leaders on a company-by-company basis primarily through
the use of fundamental financial analysis, which includes an analysis of ESG factors that the Fund’s Sub-Adviser has determined
are financially material. The Fund is not constrained by any particular investment style, and may therefore invest in “growth”
stocks, “value” stocks or a combination of both. Additionally, it may buy stocks in any sector or industry, and it is not
limited to investing in securities of a specific market capitalization.
Please also see the response to Comment 7 below.
c. Comment. Please disclose the criteria used to meet the Fund’s 80% policy.
Response. Please see the response to Comment 3(b)
above.
d. Comment. Please clarify what is meant by “underlying revenue” in the following disclosure: “This taxonomy
defines the investable universe for this Fund by identifying businesses that derive at least 20% of their underlying revenue from
products and/or services to improve quality of life, broaden economic participation, and meet basic needs” (emphasis added). Please
also clarify whether this 20% test is a component of the “social leaders” definition.
Response. In response to the Staff’s comment,
the italicized phrase has been replaced with “derive significant revenues (i.e., at least 20% of revenues) from social markets.”
Please also see the response to Comment 3(b) above.
3
4. Comment. Please explain how environmental, social and governance (“ESG”) is defined and the specific ESG factors
that the Fund focuses on.
Response. The Registrant believes that its current
disclosure adequately describes the specific factors on which the Fund focuses.
5. Comment. Please clarify the investment process used to determine whether a company is a “social leaders” company.”
For example, please reconcile the following disclosures to clarify what is meant by a “sustainable investing” approach, “integrating
[ESG] analysis and ratings” into portfolio construction and the “use of fundamental analysis, including ESG analysis:”
“The Global Social Leaders Fund follows a sustainable
investing approach, investing in companies that the Sub-Adviser believes are well positioned to benefit from the transition to a more
sustainable global economy, integrating environmental, social and governance (“ESG”) analysis and ratings into portfolio
construction and managing the portfolio within certain risk parameters relative to the Fund’s benchmark universe of MSCI ACWI Index
companies” (emphasis added).
“The Fund’s Sub-Adviser selects equity securities on
a company-by-company basis primarily through the use of fundamental analysis, including ESG analysis” (emphasis added).
Response. Please see the response to Comment 3(b)
above, the disclosure which immediately follows the first paragraph of the referenced disclosure in this comment.
6. Comment. Please disclose (i) whether ESG criteria are applied to every investment or to only some investments made by the Fund,
and (ii) whether ESG is the exclusive factor or one of several factors considered by the Fund.
Response. The ESG criteria are applied to each
holding in the Fund’s portfolio, except to the extent the Fund “may invest in exchange traded funds (ETFs), credit default
swaps on indices, swap contracts or other instruments for cash management or hedging purposes, or to gain temporary market exposures,”
as disclosed in the Environmental, Social and Governance (ESG) Criteria section in Item 9. As noted in the response to Comment 3(b) above,
the Sub-Adviser also considers fundamental factors in selecting investments for the Fund.
7. Comment. If the Fund relies on a third-party ESG data, scoring or ratings service provider, please identify the third-party
service provider or, if there are multiple providers, please identify the primary third-party service provider. Please also summarize
the third-party service provider’s methodology and criteria used to generate sustainability data, scores or ratings.
4
Response. The Fund’s Sub-Adviser makes its
own assessment of whether a company is well positioned to benefit from the transition to a more sustainable economy based on data provided
by the company itself or by third-party data providers. The Registrant has reviewed the Fund’s current disclosure and believes that
it meets the requirements in Item 4(a) of Form N-1A. Accordingly, the Registrant declines to make the requested change.
8. Comment. If the Fund does not rely on a third-party ESG data, scoring or ratings service provider, please briefly disclose
how proprietary data sources used by the Fund’s sub-adviser are integrated into the Fund’s investment process to determine
companies that are “social leaders.” Please also disclose any risks associated with the use of such proprietary data sources.
Response. Please see the response to Comment 7
above. Also, in response to the Staff’s comment, the Registrant has revised Management Risk in the Principal Risks section, as follows:
“Management Risk The Fund is actively managed. The
investment techniques and decisions of the investment adviser and the Fund’s portfolio manager(s), including the investment adviser’s
assessment of a company’s ESG profile when selecting investments for the Fund, may not produce the desired results and may adversely
impact the Fund’s performance, including relative to other funds that do not consider ESG factors or come to different conclusions
regarding such factors. Further, in evaluating a company, the Adviser is often dependent upon information and data obtained from the
company itself or from third-party data providers that may be incomplete or inaccurate, which could cause the investment adviser or the
Fund’s portfolio manager(s) to incorrectly assess a company’s ESG profile.”
9. Comment. Please clarify what is meant by “managing the portfolio within certain risk parameters” in the following
disclosure: “The Global Social Leaders Fund follows a sustainable investing approach, investing in companies that the Sub-Adviser
believes are well positioned to benefit from the transition to a more sustainable global economy, integrating environmental, social and
governance (“ESG”) analysis and ratings into portfolio construction and managing the portfolio within certain risk parameters
relative to the Fund’s benchmark universe of MSCI ACWI Index companies” (emphasis added).
Response. The Registrant believes that the referenced
disclosure will be sufficiently understood by a reasonable investor. In response to the Staff’s comment, however, the Registrant
has revised the referenced disclosure to add the following parenthetical following the phrase “certain risk parameters:” “(e.g.,
sector and regional exposure).”
10. Comment. The following disclosure suggests that the Fund’s Sub-Adviser determines whether a particular company addresses
societal challenges: “Under normal market conditions, the Fund invests at least 80% of its net assets (plus any borrowings for investment
purposes) in companies whose products or services the Fund’s Sub-Adviser has determined address societal challenges…”
(emphasis added). In the Staff’s view, it is not sufficient to rely on the adviser’s or sub-adviser’s judgment in making
such a determination. Please disclose the factors considered, and the criteria used, to determine what types of companies address societal
challenges (e.g., a screen, factors used by a screen or an index).
5
Response. The Registrant respectfully submits that
the Sub-Adviser’s determination of whether a company is or is not a “social leader” is a partially subjective determination.
As disclosed in Item 9, the companies in which the Fund may invest do not necessarily meet exemplary standards in all aspects of sustainability
or ESG performance because no company is perfect – all company ESG profiles have strengths and weaknesses just as all investment
decisions involve assessments of opportunities and risks. Accordingly, the Registrant believes that its investment process, as currently
disclosed, adequately describes the criteria used to determine what companies are “social leaders,” and satisfies the requirements
of Items 4 and 9 of Form N-1A.
11. Comment. Given that the term “global” is used in the Fund’s name, please expressly describe how the Fund
will invest its assets in investments that are tied economically to a number of countries throughout the world. See Investment
Co. Act Rel. No. 24828, at n. 42 (Jan. 17, 2001).
Response. In response to your comment, the Fund’s
Principal Investment Strategies section has been revised, as follows:
“Under normal market conditions, the Fund will invest primarily
in equity securities (such as common stocks, preferred stocks and securities convertible into common and preferred stocks) of companies
located around the world, including at least 40% of its net assets in securities of non-US issuers companies organized
or located outside the United States or doing a substantial amount of business outside the United States, including those located
in emerging markets.”
12. Comment. Given that the term “global” is used in the Fund’s name, please consider describing the Fund’s
policy for how it will invest its assets in investments that are tied economically to a number of countries throughout the world in unfavorable
market conditions. For example, instead of at least 40% of its net assets, will the Fund invest at least 30% of its net assets in securities
of non-US issuers in unfavorable market conditions? If the Fund does not have such a policy, please note supplementally.
Response. The Registrant does not currently have
such a policy.
13. Comment. With respect to the following disclosure, please consider deleting the phrase “such as,” as this phrase
suggests that the Fund has not summarized the totality of its principal investment strategies and associated investment instruments: “Under
normal market conditions, the Fund will invest primarily in equity securities (such as common stocks, preferred stocks and securities
convertible into common and preferred stocks) of companies located around the world…” (emphasis added).
6
Response. The Registrant believes that the referenced
phrase helps clarify the types of equity securities in which the Fund will invest. Accordingly, the Registrant respectfully declines to
make the requested change.
14. Comment. Please confirm supplementally that all principal investment strategies and principal risks of the Fund are summarized
in Item 4, with more detailed disclosure in Item 9.
Response. The Registrant so