Correspondence 0001193125-24-186296 from BLACKROCK BOND FUND, INC. (CIK 0000276463)
BLACKROCK BOND FUND, INC. (CIK 0000276463)
Date: July 26, 2024 · CIK: 0000276463 · Accession: 0001193125-24-186296
AI Filing Summary & Sentiment
File numbers found in text: 811-02857, 811-05603, 811-05742, 811-06414, 811-06500, 811-06540, 811-06660, 811-07332, 811-07478, 811-07642, 811-07885, 811-07899, 811-08081, 811-08162, 811-08573, 811-08621, 811-09191, 811-10331, 811-10337, 811-10339, 811-21348, 811-21434, 811-21835, 811-22061, 811-22603, 811-23339, 811-23341, 811-23343, 811-23344, 811-23402, 811-23511
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Response to Staff Comments on the Annual Reports of Funds Listed on Appendix A
Dear Mr. Manion:
On behalf of the funds set forth in Appendix A (each, a “Fund” and collectively, the “Funds”), this letter responds to comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to the undersigned and Robert Harrington of Willkie Farr & Gallagher LLP by telephone on June 10, 2024 regarding the Annual Reports to Shareholders on Form N-CSR (each, an “Annual Report”) and the Annual Report for Registered Investment Companies on Form N-CEN (each, a “Form N-CEN” and together with the Annual Reports, the “Reports”) of each Fund for the fiscal year ended as of the date specified for such Fund in Appendix A.
For your convenience, the substance of the Staff’s comments has been restated below. We have discussed the Staff’s comments with representatives of the Funds. Each Fund’s joint or individual responses to each comment, as applicable, are set out immediately under the restated comment. Please note that we have not independently verified information provided by the Funds. Unless otherwise indicated, defined terms used herein have the meanings set forth in the relevant Report(s).
Comment No. 1: According to its Annual Report, BlackRock Strategic Income Opportunities Portfolio held a Russian Federation bond denominated in rubles as of December 31, 2023. Given the sanctions levied against the Russian Federation in connection with the ongoing war in Ukraine, please explain supplementally how the bond was valued, as it appears to be classified as Level 2 in the fair value hierarchy in the Annual Report.
BRUSSELS CHICAGO DALLAS FRANKFURT HOUSTON LONDON LOS ANGELES MILAN
MUNICH NEW YORK PALO ALTO PARIS ROME SAN FRANCISCO WASHINGTON
Response No. 1: The Russian Federation bond denominated in rubles with a value of $5,055,957, shown on page 85 of the Annual Report of BlackRock Strategic Income Opportunities Portfolio, was classified as Level 2 on the fair value hierarchy disclosure table starting on Page 151 in the Asset-Foreign Government Obligations line item. The security was valued using a third-party pricing vendor whose price considers information such as observable transactions of the exact and/or similar securities and market observable dealer quotes. Securities fair valued using market observable inputs would be classified as Level 2 by the Fund in accordance with ASC 820.
Comment No. 2: Please confirm whether any Funds have meaningful positions in the equity tranches of any asset-backed securities (“ABS”), collateralized debt obligations (“CDOs”) or similar securities. If so, please consider including disclosures related to accounting for income and disclosures on how the interest and yield rates are determined with respect to such investments.
Response No. 2: The Funds do not hold meaningful positions in the equity tranches of ABS, CDOs or similar securities. If the Funds hold meaningful positions in these securities in the future, BlackRock will consider adding the requested disclosure regarding accounting for income and interest and yield rate calculations in connection with such Funds’ investments in equity tranches of ABS, CDOs and similar securities in future financial statements.
* * * * * * * * *
Please do not hesitate to contact me at (212) 728-8955 if you have comments or if you require additional information regarding the Reports.
Respectfully submitted,
/s/ Bissie K. Bonner
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CORRESP 1 filename1.htm SEC Comment Response Letter 787 Seventh Avenue New York, NY 10019-6099 Tel: 212 728 8000 Fax: 212 728 8111 July 26, 2024 VIA EDGAR Mr. David Manion Division of Investment Management Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Response to Staff Comments on the Annual Reports of Funds Listed on Appendix A Dear Mr. Manion: On behalf of the funds set forth in Appendix A (each, a “Fund” and collectively, the “Funds”), this letter responds to comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to the undersigned and Robert Harrington of Willkie Farr & Gallagher LLP by telephone on June 10, 2024 regarding the Annual Reports to Shareholders on Form N-CSR (each, an “Annual Report”) and the Annual Report for Registered Investment Companies on Form N-CEN (each, a “Form N-CEN” and together with the Annual Reports, the “Reports”) of each Fund for the fiscal year ended as of the date specified for such Fund in Appendix A. For your convenience, the substance of the Staff’s comments has been restated below. We have discussed the Staff’s comments with representatives of the Funds. Each Fund’s joint or individual responses to each comment, as applicable, are set out immediately under the restated comment. Please note that we have not independently verified information provided by the Funds. Unless otherwise indicated, defined terms used herein have the meanings set forth in the relevant Report(s). Comment No. 1: According to its Annual Report, BlackRock Strategic Income Opportunities Portfolio held a Russian Federation bond denominated in rubles as of December 31, 2023. Given the sanctions levied against the Russian Federation in connection with the ongoing war in Ukraine, please explain supplementally how the bond was valued, as it appears to be classified as Level 2 in the fair value hierarchy in the Annual Report. BRUSSELS CHICAGO DALLAS FRANKFURT HOUSTON LONDON LOS ANGELES MILAN MUNICH NEW YORK PALO ALTO PARIS ROME SAN FRANCISCO WASHINGTON Response No. 1: The Russian Federation bond denominated in rubles with a value of $5,055,957, shown on page 85 of the Annual Report of BlackRock Strategic Income Opportunities Portfolio, was classified as Level 2 on the fair value hierarchy disclosure table starting on Page 151 in the Asset-Foreign Government Obligations line item. The security was valued using a third-party pricing vendor whose price considers information such as observable transactions of the exact and/or similar securities and market observable dealer quotes. Securities fair valued using market observable inputs would be classified as Level 2 by the Fund in accordance with ASC 820. Comment No. 2: Please confirm whether any Funds have meaningful positions in the equity tranches of any asset-backed securities (“ABS”), collateralized debt obligations (“CDOs”) or similar securities. If so, please consider including disclosures related to accounting for income and disclosures on how the interest and yield rates are determined with respect to such investments. Response No. 2: The Funds do not hold meaningful positions in the equity tranches of ABS, CDOs or similar securities. If the Funds hold meaningful positions in these securities in the future, BlackRock will consider adding the requested disclosure regarding accounting for income and interest and yield rate calculations in connection with such Funds’ investments in equity tranches of ABS, CDOs and similar securities in future financial statements. * * * * * * * * * Please do not hesitate to contact me at (212) 728-8955 if you have comments or if you require additional information regarding the Reports. Respectfully submitted, /s/ Bissie K. Bonner Bissie K. Bonner cc: Janey Ahn, Esq., BlackRock, Inc. Jessica Holly Esq., BlackRock, Inc. Gladys Chang, Esq., BlackRock, Inc. Bomi Lee, Esq., BlackRock, Inc. Jesse Kean, Esq. Sidley Austin LLP Elliot J. Gluck, Esq., Willkie Farr & Gallagher LLP Robert Harrington, Esq., Willkie Farr & Gallagher LLP - 2 - Appendix A Funds File No. Fiscal Year-End of Report BlackRock Bond Fund, Inc. 811-02857 BlackRock Sustainable Total Return Fund 9/30/2023 BlackRock Total Return Fund 9/30/2023 BlackRock California Municipal Income Trust 811-10331 7/31/2023 BlackRock Strategic Global Bond Fund, Inc. 811-05603 12/31/2023 BlackRock ETF Trust 811-23402 BlackRock Future Climate and Sustainable Economy ETF 7/31/2023 BlackRock Future Financial and Technology ETF 7/31/2023 BlackRock Future Health ETF 7/31/2023 BlackRock Future Tech ETF 7/31/2023 BlackRock Future U.S. Themes ETF 7/31/2023 BlackRock Large Cap Value ETF 7/31/2023 BlackRock U.S. Carbon Transition Readiness ETF 7/31/2023 BlackRock U.S. Equity Factor Rotation ETF 7/31/2023 BlackRock World ex U.S. Carbon Transition Readiness ETF 7/31/2023 BlackRock ETF Trust II 811-23511 BlackRock AAA CLO ETF 7/31/2023 BlackRock Flexible Income ETF 7/31/2023 BlackRock Floating Rate Loan ETF 7/31/2023 BlackRock High Yield Muni Income Bond ETF 7/31/2023 BlackRock Intermediate Muni Income Bond ETF 7/31/2023 BlackRock Short-Term California Muni Bond ETF 7/31/2023 - 3 - Funds File No. Fiscal Year-End of Report BlackRock Funds 811-05742 BlackRock Advantage Small Cap Growth Fund 9/30/2023 iShares Municipal Bond Index Fund 12/31/2023 iShares Short-Term TIPS Bond Index Fund 12/31/2023 BlackRock Funds II 811-22061 BlackRock Managed Income Fund 12/31/2023 BlackRock Funds III 811-07332 BlackRock Cash Funds: Institutional 12/31/2023 BlackRock Cash Funds: Treasury 12/31/2023 BlackRock Diversified Equity Fund 12/31/2023 BlackRock LifePath® Dynamic 2025 Fund 12/31/2023 BlackRock LifePath® Dynamic 2030 Fund 12/31/2023 BlackRock LifePath® Dynamic 2035 Fund 12/31/2023 BlackRock LifePath® Dynamic 2040 Fund 12/31/2023 BlackRock LifePath® Dynamic 2045 Fund 12/31/2023 BlackRock LifePath® Dynamic 2050 Fund 12/31/2023 BlackRock LifePath® Dynamic 2055 Fund 12/31/2023 BlackRock LifePath® Dynamic 2060 Fund 12/31/2023 BlackRock LifePath® Dynamic 2065 Fund 12/31/2023 BlackRock LifePath® Dynamic Retirement Fund 12/31/2023 BlackRock LifePath® Index 2025 Fund 12/31/2023 BlackRock LifePath® Index 2030 Fund 12/31/2023 BlackRock LifePath® Index 2035 Fund 12/31/2023 - 4 - Funds File No. Fiscal Year-End of Report BlackRock LifePath® Index 2040 Fund 12/31/2023 BlackRock LifePath® Index 2045 Fund 12/31/2023 BlackRock LifePath® Index 2050 Fund 12/31/2023 BlackRock LifePath® Index 2055 Fund 12/31/2023 BlackRock LifePath® Index 2060 Fund 12/31/2023 BlackRock LifePath® Index 2065 Fund 12/31/2023 BlackRock LifePath® Index Retirement Fund 12/31/2023 iShares MSCI Total International Index Fund 12/31/2023 iShares Russell 1000 Large-Cap Index Fund 12/31/2023 iShares S&P 500 Index Fund 12/31/2023 iShares U.S. Aggregate Bond Index Fund 12/31/2023 BlackRock Funds IV 811-23341 BlackRock Systematic Multi-Strategy Fund 12/31/2023 BlackRock Funds V 811-23339 BlackRock Core Bond Portfolio 9/30/2023 BlackRock GNMA Portfolio 9/30/2023 BlackRock High Yield Bond Portfolio 9/30/2023 BlackRock Impact Mortgage Fund 9/30/2023 BlackRock Income Fund 9/30/2023 BlackRock Inflation Protected Bond Portfolio 12/31/2023 BlackRock Low Duration Bond Portfolio 9/30/2023 BlackRock Strategic Income Opportunities Portfolio 12/31/2023 BlackRock Sustainable High Yield Bond Fund 9/30/2023 - 5 - Funds File No. Fiscal Year-End of Report BlackRock Sustainable Low Duration Bond Fund 9/30/2023 BlackRock Funds VI 811-23344 BlackRock Advantage CoreAlpha Bond Fund 12/31/2023 BlackRock Index Funds, Inc. 811-07899 iShares MSCI EAFE International Index Fund 12/31/2023 iShares Russell 2000 Small-Cap Index Fund 12/31/2023 BlackRock Long-Term Municipal Advantage Trust 811-21835 7/31/2023 BlackRock MuniAssets Fund, Inc. 811-07642 7/31/2023 BlackRock Municipal 2030 Target Term Trust 811-22603 7/31/2023 BlackRock Municipal Income Fund, Inc. 811-21348 7/31/2023 BlackRock Municipal Income Trust 811-10339 7/31/2023 BlackRock MuniHoldings California Quality Fund, Inc. 811-08573 7/31/2023 BlackRock MuniHoldings Fund, Inc. 811-08081 7/31/2023 BlackRock MuniHoldings New Jersey Quality Fund, Inc. 811-08621 7/31/2023 BlackRock MuniHoldings Quality Fund II, Inc. 811-09191 7/31/2023 BlackRock MuniVest Fund II, Inc. 811-07478 7/31/2023 BlackRock MuniYield Fund, Inc. 811-06414 7/31/2023 BlackRock MuniYield New York Quality Fund, Inc. 811-06500 7/31/2023 BlackRock MuniYield Quality Fund II, Inc. 811-06660 7/31/2023 BlackRock MuniYield Quality Fund III, Inc. 811-06540 7/31/2023 BlackRock MuniYield Quality Fund, Inc. 811-06660 7/31/2023 BlackRock New York Municipal Income Trust 811-10337 7/31/2023 Master Bond LLC 811-21434 - 6 - Funds File No. Fiscal Year-End of Report Master Total Return Portfolio 9/30/2023 Master Investment Portfolio 811-08162 Diversified Equity Master Portfolio 12/31/2023 International Tilts Master Portfolio 12/31/2023 Large Cap Index Master Portfolio 12/31/2023 Money Market Master Portfolio 12/31/2023 S&P 500 Index Master Portfolio 12/31/2023 Total International ex U.S. Index Master Portfolio 12/31/2023 Treasury Money Market Master Portfolio 12/31/2023 U.S. Total Bond Index Master Portfolio 12/31/2023 Master Investment Portfolio II 811-23343 Advantage CoreAlpha Bond Master Portfolio 12/31/2023 Quantitative Master Series LLC 811-07885 Master Small Cap Index Series 12/31/2023 - 7 -