Correspondence 0001076598-25-000004 from Eaton Vance Mutual Funds Trust (CIK 0000745463)
Eaton Vance Mutual Funds Trust (CIK 0000745463)
Date: March 31, 2025 · CIK: 0000745463 · Accession: 0001076598-25-000004
AI Filing Summary & Sentiment
File numbers found in text: 811-02258, 811-04015, 811-08342, 811-09837, 811-09987, 811-10065, 811-10387, 811-10389, 811-21574, 811-22048, 811-22350, 811-22424, 811-22714, 811-22896, 811-25174
Referenced dates: November 22, 2019
Letter
VIA EDGAR Division of Investment Management New York Regional Office 100 Pearl Street, Suite 20-100 New York, NY 10004-2616 Re: Eaton Vance Floating Rate Portfolio/MA (File No. 811-09987); Eaton Vance Floating-Rate Income Trust (File No. 811-25174); Eaton Vance Mutual Funds Trust (File No. 811-04015); Eaton Vance Series Fund, Inc. (File No. 811-22714); Eaton Vance Series Trust II (File No. 811-02258); Emerging Markets Local Income Portfolio (File No. 811-22048); Global Macro Absolute Return Advantage Portfolio (File No. 811-22424); Global Macro Capital Opportunities Portfolio (File No. 811-22896); Global Macro Portfolio (File No. 811-08342); Global Opportunities Portfolio (File No. 811-22350); Tax Managed Small Cap Portfolio (File No. 811-10065); Tax-Managed International Equity Portfolio (File No. 811-10389); Tax-Managed Multi-Cap Growth Portfolio (File No. 811-09837); and Tax-Managed Value Portfolio (File No. 811-10387) (each, a “Registrant”)
Dear Mr. Ellington,
This letter is in response to the comments you provided telephonically to Lisa Henry of Ropes & Gray LLP on March 3, 2025 with respect to the Forms N-CSR and Forms N-CEN filed by the series of the Registrants listed on Appendix A attached hereto (each, a “Fund” and collectively, the “Funds”) for the fiscal periods ended May 31, 2024, July 31, 2024, and October 31, 2024. The comments and Registrants’ responses thereto are set forth below. Changes referenced in responses below will be incorporated into Forms N-CSR and Forms N-CEN and other applicable regulatory filings going forward, as noted below.
Comments and Responses
1. Comment: In the footnotes to the schedule of investments for Funds that identify level 3 securities, please disclose that the value was determined using significant unobservable inputs as required by Article 12-12 footnote 9 of Regulation S-X.
Response: The footnote to the schedule of investments that identifies Level 3 securities also includes a reference to the Fair Value Measurements Note to the Financial Statements, which includes a description of the inputs for Level 1, Level 2 and Level 3 securities. Each Registrant believes that this disclosure meets the requirements of Article 12-12 footnote 9 of Regulation S-X.
2. Comment: Several Funds include a footnote to the schedule of investments that states, “the stated interest rate represents the weighted average interest rate at [period end] of contracts within the senior loan facility.” In future financial statements, please include additional information about the various rates rather than including only a weighted average rate. For additional guidance, refer to the AICPA Expert Panel Meeting Minutes dated February 20, 2018.
Response: For Funds with multiple contracts within the senior loan facility for which a weighted average interest rate at period-end has been presented, the Registrants will replace the weighted average interest rate with the range of interest rates in effect at period-end, with appropriate disclosure of the related index and spread associated with such range.
3. Comment: Eaton Vance Global Income Builder Fund and Eaton Vance Global Equity Income Fund disclosed material tax reclaims receivables as of the most recent fiscal year end. Please explain to which country or countries these receivables relate and how the Funds monitor the collectability of those receivables.
Response: For the fiscal year ended October 31, 2024, the tax reclaims receivables reflected in Eaton Vance Global Income Builder Fund’s Statement of Assets and Liabilities represent withholding tax reclaims primarily from France, Germany and Switzerland. For the fiscal year ended October 31, 2024, the tax reclaims receivables reflected in Eaton Vance Global Equity Income Fund’s Statement of Assets and Liabilities represent withholding tax reclaims primarily from Germany and Switzerland. Each Fund’s custodian, State Street Bank and Trust Company (the “Custodian”), files the statutory reclaims as directed by each Fund’s administrator, Eaton Vance Management (the “Administrator”). The Administrator reviews open reclaims with the Custodian’s tax reclaim specialists no less frequently than monthly to ensure that all relevant documentation has been filed and that the reclaims are in process.
4. Comment: With respect to Eaton Vance Floating-Rate Income Trust, please include disclosure responsive to Items 4(i) and 4(j) in all future Form N-CSR filings, even if those items are not applicable to the Registrant.
Response: Items 4(i) and 4(j) were inadvertently omitted from the Form N-CSR filing for Eaton Vance Floating-Rate Income Trust, although not applicable. The Registrant will add the requested disclosure in future filings.
5. Comment: Please confirm that Eaton Vance Emerging Markets Debt Opportunities Fund has complied with the shareholder notice requirements regarding its return of capital per Section 19(a) of the Investment Company Act of 1940. Please refer to IM-DCFO 2019-02 Dear CFO letter dated November 22, 2019.
Response: The Registrant confirms that Eaton Vance Emerging Markets Debt Opportunities Fund complied with the shareholder notice requirements regarding its return of capital per Section 19(a) of the Investment Company Act of 1940.
6. Comment: In the Form N-CEN filed on January 14, 2025, Eaton Vance Floating Rate Portfolio reports sharing a line of credit with the International (Cayman Islands) Floating Rate Income Portfolio, but does not include the Fund’s SEC file number in Item C.20.a.iv. Please explain or revise going forward.
Response: The Registrant notes that the International (Cayman Islands) Floating Rate Income Portfolio does not have an SEC file number and, accordingly, none was included in Item C.20.a.iv of Form N-CEN.
* * *
* * *
If you have any questions or comments concerning the foregoing, please contact the undersigned at 617-951-7780.
Very truly yours,
/s/ Lisa Henry
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CORRESP
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filename1.htm
March 31, 2025
VIA EDGAR
Mr. Kenneth Ellington
U.S. Securities and Exchange Commission
Division of Investment Management
Disclosure Review and Accounting Office
New York Regional Office
100 Pearl Street, Suite 20-100
New York, NY 10004-2616
Re: Eaton Vance Floating Rate Portfolio/MA (File No. 811-09987); Eaton Vance Floating-Rate Income Trust (File No. 811-25174); Eaton Vance
Mutual Funds Trust (File No. 811-04015); Eaton Vance Series Fund, Inc. (File No. 811-22714); Eaton Vance Series Trust II (File No. 811-02258);
Emerging Markets Local Income Portfolio (File No. 811-22048); Global Macro Absolute Return Advantage Portfolio (File No. 811-22424); Global
Macro Capital Opportunities Portfolio (File No. 811-22896); Global Macro Portfolio (File No. 811-08342); Global Opportunities Portfolio
(File No. 811-22350); Tax Managed Small Cap Portfolio (File No. 811-10065); Tax-Managed International Equity Portfolio (File No. 811-10389);
Tax-Managed Multi-Cap Growth Portfolio (File No. 811-09837); and Tax-Managed Value Portfolio (File No. 811-10387) (each, a “Registrant”)
Dear Mr. Ellington,
This letter is in response to the comments you
provided telephonically to Lisa Henry of Ropes & Gray LLP on March 3, 2025 with respect to the Forms N-CSR and Forms N-CEN filed by
the series of the Registrants listed on Appendix A attached hereto (each, a “Fund” and collectively, the “Funds”)
for the fiscal periods ended May 31, 2024, July 31, 2024, and October 31, 2024. The comments and Registrants’ responses thereto
are set forth below. Changes referenced in responses below will be incorporated into Forms N-CSR and Forms N-CEN and other applicable
regulatory filings going forward, as noted below.
Comments and Responses
1. Comment: In the footnotes to the schedule of investments for Funds
that identify level 3 securities, please disclose that the value was determined using significant unobservable inputs as required by Article
12-12 footnote 9 of Regulation S-X.
Response:
The footnote to the schedule of investments that identifies Level 3 securities also includes a reference to the Fair Value Measurements
Note to the Financial Statements, which includes a description of the inputs for Level 1, Level 2 and Level 3 securities. Each Registrant
believes that this disclosure meets the requirements of Article 12-12 footnote 9 of Regulation S-X.
2. Comment: Several Funds include a footnote to the schedule of investments
that states, “the stated interest rate represents the weighted average interest rate at [period end] of contracts within the senior
loan facility.” In future financial statements, please include additional information about the various rates rather than including
only a weighted average rate. For additional guidance, refer to the AICPA Expert Panel Meeting Minutes dated February 20, 2018.
Response:
For Funds with multiple contracts within the senior loan facility for which a weighted average interest rate at period-end has been presented,
the Registrants will replace the weighted average interest rate with the range of interest rates in effect at period-end, with appropriate
disclosure of the related index and spread associated with such range.
3. Comment: Eaton Vance Global Income Builder Fund and Eaton Vance Global
Equity Income Fund disclosed material tax reclaims receivables as of the most recent fiscal year end. Please explain to which country
or countries these receivables relate and how the Funds monitor the collectability of those receivables.
Response:
For the fiscal year ended October 31, 2024, the tax reclaims receivables reflected in Eaton Vance Global Income Builder Fund’s Statement
of Assets and Liabilities represent withholding tax reclaims primarily from France, Germany and Switzerland. For the fiscal year ended
October 31, 2024, the tax reclaims receivables reflected in Eaton Vance Global Equity Income Fund’s Statement of Assets and Liabilities
represent withholding tax reclaims primarily from Germany and Switzerland. Each Fund’s custodian, State Street Bank and Trust Company
(the “Custodian”), files the statutory reclaims as directed by each Fund’s administrator, Eaton Vance Management (the
“Administrator”). The Administrator reviews open reclaims with the Custodian’s tax reclaim specialists no less frequently
than monthly to ensure that all relevant documentation has been filed and that the reclaims are in process.
4. Comment: With respect to Eaton Vance Floating-Rate Income Trust,
please include disclosure responsive to Items 4(i) and 4(j) in all future Form N-CSR filings, even if those items are not applicable to
the Registrant.
Response:
Items 4(i) and 4(j) were inadvertently omitted from the Form N-CSR filing for Eaton Vance Floating-Rate Income Trust, although not applicable.
The Registrant will add the requested disclosure in future filings.
5. Comment: Please confirm that Eaton Vance Emerging Markets Debt Opportunities
Fund has complied with the shareholder notice requirements regarding its return of capital per Section 19(a) of the Investment Company
Act of 1940. Please refer to IM-DCFO 2019-02 Dear CFO letter dated November 22, 2019.
Response:
The Registrant confirms that Eaton Vance Emerging Markets Debt Opportunities Fund complied with the shareholder notice requirements regarding
its return of capital per Section 19(a) of the Investment Company Act of 1940.
6. Comment: In the Form N-CEN filed on January 14, 2025, Eaton Vance
Floating Rate Portfolio reports sharing a line of credit with the International (Cayman Islands) Floating Rate Income Portfolio, but does
not include the Fund’s SEC file number in Item C.20.a.iv. Please explain or revise going forward.
Response:
The Registrant notes that the International (Cayman Islands) Floating Rate Income Portfolio does not have an SEC file number and, accordingly,
none was included in Item C.20.a.iv of Form N-CEN.
* * *
* * *
If you have any questions or
comments concerning the foregoing, please contact the undersigned at 617-951-7780.
Very truly yours,
/s/ Lisa Henry
cc: Sarah Clinton, Ropes & Gray LLP
Stephanie
Rosander, Eaton Vance Management
Appendix A
File #
Registrant Name
Series ID
Series Name
FYE Reviewed
811-09987
Eaton Vance Floating Rate Portfolio/MA
S000005230
Eaton Vance Floating Rate Portfolio
10/31/2024
811-21574
Eaton Vance Floating-Rate Income Trust
N/A
Eaton Vance Floating-Rate Income Trust
5/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000047244
Eaton Vance Emerging and Frontier Countries Equity Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000017968
Eaton Vance Emerging Markets Local Income Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000005287
Eaton Vance Floating-Rate & High Income Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000019373
Eaton Vance Floating-Rate Advantage Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000005286
Eaton Vance Floating-Rate Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000005291
Eaton Vance Global Equity Income Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000008473
Eaton Vance Global Income Builder Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000029759
Eaton Vance Global Macro Absolute Return Advantage Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000017966
Eaton Vance Global Macro Absolute Return Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000017967
Eaton Vance Global Sovereign Opportunities Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000005288
Eaton Vance Government Opportunities Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000005289
Eaton Vance High Income Opportunities Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000033949
Eaton Vance Multi-Asset Credit Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000005290
Eaton Vance Short Duration Government Income Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000042789
Eaton Vance Short Duration High Income Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000005301
Eaton Vance Strategic Income Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000005292
Eaton Vance Tax-Managed Equity Asset Allocation Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000005281
Eaton Vance Tax-Managed Multi-Cap Growth Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000005283
Eaton Vance Tax-Managed Small-Cap Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000005285
Eaton Vance Tax-Managed Value Fund
10/31/2024
811-04015
Eaton Vance Mutual Funds Trust
S000005279
Parametric Tax-Managed International Equity Fund
10/31/2024
811-22714
Eaton Vance Series Fund, Inc
S000038184
Eaton Vance Emerging Markets Debt Opportunities Fund
7/31/2024
811-02258
Eaton Vance Series Trust II
S000004984
Eaton Vance Income Fund of Boston
10/31/2024
811-22048
Emerging Markets Local Income Portfolio
S000017994
Emerging Markets Local Income Portfolio
10/31/2024
811-22424
Global Macro Absolute Return Advantage Portfolio
S000029761
Global Macro Absolute Return Advantage Portfolio
10/31/2024
811-22896
Global Macro Capital Opportunities Portfolio
S000043509
Global Macro Capital Opportunities Portfolio
10/31/2024
811-08342
Global Macro Portfolio
S000005247
Global Macro Portfolio
10/31/2024
811-22350
Global Opportunities Portfolio
S000027417
Global Opportunities Portfolio
10/31/2024
811-10065
Tax-Managed Small-Cap Portfolio
S000005252
Tax Managed Small Cap Portfolio
10/31/2024
811-10389
Tax-Managed International Equity Portfolio
S000005249
Tax-Managed International Equity Portfolio
10/31/2024
811-09837
Tax-Managed Multi-Cap Growth Portfolio
S000005251
Tax Managed Multi Cap Growth Portfolio
10/31/2024
811-10387
Tax-Managed Value Portfolio
S000005253
Tax-Managed Value Portfolio
10/31/2024