Correspondence 0001137439-23-000572 from DELAWARE GROUP GOVERNMENT FUND (CIK 0000769220)
DELAWARE GROUP GOVERNMENT FUND (CIK 0000769220)
Date: May 1, 2023 · CIK: 0000769220 · Accession: 0001137439-23-000572
AI Filing Summary & Sentiment
File numbers found in text: 333-270420, 811-04304
Letter
Attention: Jeff Long and Jaea Hahn Delaware Group Government Fund (Registrant) File No. 333-270420 File No. 811-04304 Registration Statement on Form N-14 and Request for Acceleration
Dear Mr. Long and Ms. Hahn:
The above referenced Registration Statement on Form N-14, which was filed on March 9, 2023 and amended through a pre-effective amendment on May 1, 2023 (the “Registration Statement”), was filed with the Securities and Exchange Commission pursuant to the Securities Act of 1933, as amended, for the purpose of registering Class A, Class C and Institutional Class shares of Delaware Strategic Income Fund (the “Acquiring Fund”), a series of the Registrant, that will be issued to shareholders of Delaware Ivy Strategic Income Fund, a series of Ivy Funds (the “Acquired Fund”), in connection with a transfer of substantially all of the assets of the Acquired Fund to the Acquiring Fund, pursuant to an Agreement and Plan of Reorganization, a form of which was included in the Registration Statement.
On behalf of the above referenced Registrant and its principal underwriter, Delaware Distributors, L.P., and pursuant to the requirements of Rule 461 under the Securities Act of 1933, we respectfully request that the effectiveness of the Registrant’s Registration Statement on Form N-14 be accelerated to Tuesday, May 2, 2023, or as soon as practicable thereafter. A definitive Prospectus/Proxy Statement will be filed and mailed to Acquired Fund shareholders shortly thereafter. It is our understanding that you have previously discussed the possible acceleration of the Registration Statement with Miranda Sturgis and Taylor Brody of Stradley Ronon Stevens & Young, LLP.
Please contact Taylor Brody at (215) 564-8071 or Jonathan Kopcsik at (215) 564-8099 if you have any questions or comments regarding this filing or the acceleration request.
Sincerely,
/s/ Shawn K. Lytle
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Delaware Group Government Fund
100 Independence, 610 Market Street
Philadelphia, Pennsylvania 19106-2354
Delaware Distributors, L.P.
100 Independence, 610 Market Street
Philadelphia, Pennsylvania 19106-2354
May 1, 2023
Filing Desk
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attention: Jeff Long and Jaea Hahn
Re:
Delaware Group Government Fund (Registrant)
File No. 333-270420
File No. 811-04304
Registration Statement on Form N-14 and Request for Acceleration
Dear Mr. Long and Ms. Hahn:
The above referenced Registration Statement on Form N-14, which was filed on March 9, 2023 and amended through a pre-effective amendment on
May 1, 2023 (the “Registration Statement”), was filed with the Securities and Exchange Commission pursuant to the Securities Act of 1933, as amended, for the purpose of registering Class A, Class C and Institutional Class shares of Delaware Strategic
Income Fund (the “Acquiring Fund”), a series of the Registrant, that will be issued to shareholders of Delaware Ivy Strategic Income Fund, a series of Ivy Funds (the
“Acquired Fund”), in connection with a transfer of substantially all of the assets of the Acquired Fund to the Acquiring Fund, pursuant to an Agreement and Plan of Reorganization, a form of which was included in the Registration Statement.
On behalf of the above referenced Registrant and its principal underwriter, Delaware Distributors, L.P., and pursuant to the requirements
of Rule 461 under the Securities Act of 1933, we respectfully request that the effectiveness of the Registrant’s Registration Statement on Form N-14 be accelerated to Tuesday, May 2, 2023, or as soon as practicable thereafter. A definitive
Prospectus/Proxy Statement will be filed and mailed to Acquired Fund shareholders shortly thereafter. It is our understanding that you have previously discussed the possible acceleration of the Registration Statement with Miranda Sturgis and Taylor
Brody of Stradley Ronon Stevens & Young, LLP.
Please contact Taylor Brody at (215) 564-8071 or Jonathan Kopcsik at (215) 564-8099 if you have any questions or comments regarding this
filing or the acceleration request.
Sincerely,
/s/ Shawn K. Lytle
/s/ Richard Salus
Name:
Shawn K. Lytle
Name:
Richard Salus
Title:
President/Chief Executive Officer
Title:
Senior Vice President
Delaware Group Government Fund
Delaware Distributors, L.P.