SEC Company Response from Federated Hermes Income Securities Trust (CIK 0000789281) — Nov 8, 2021
Federated Hermes Income Securities Trust (CIK 0000789281)
Date: Nov. 8, 2021 · CIK: 0000789281 · Accession: 0001623632-21-001411
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File numbers found in text: 811-3181, 811-4577
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FEDERATED HERMES FUNDS
4000 Ericsson Drive
Warrendale, Pennsylvania 15086-7561
November 8, 2021
Jeremy Esperon
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549-4720
RE:
FEDERATED HERMES INCOME SECURITIES TRUST (a “Registrant”)
Federated Hermes Short-Term Income Fund (a “Fund”)
Class A2 Shares
1933 Act File No. 2-72277
1940 Act File No. 811-3181
FEDERATED HERMES SHORT-INTERMEDIATE DURATION MUNICIPAL TRUST (a “Registrant”)
Federated Hermes Short-Intermediate Municipal Fund (a “Fund)
Class A2 Shares
1933 Act File No. 33-3164
1940 Act File No. 811-4577
Dear Mr. Esperon:
The above-named registrants (each a “Registrant”
and, collectively, the “Registrants”) are filing this correspondence to respond to comments of the Staff of the Securities
and Exchange Commission (“Staff”), provided on October 26, 2021 regarding their respective funds (each a “Fund”
and, collectively, the “Funds”). These comments relate to the Registration Statements of the Registrants and their Funds filed
on September 8, 2021 as:
Federated Hermes Income Securities Trust
Post-Effective Amendment No. 229 under the Securities
Act of 1933
Amendment No. 222 under the Investment Company Act
of 1940
Federated Hermes Short-Intermediate Duration Municipal
Trust
Post-Effective Amendment No. 72 under the Securities
Act of 1933
Amendment No. 63 under the Investment Company Act
of 1940
Unless otherwise noted below, comments and responses
will apply to both Registrants and Funds.
COMMENT 1. General Comments
1. The Registrants are responsible for the accuracy and adequacy of their disclosure
notwithstanding review by the Staff.
2. The Registrants must file their responses on EDGAR no later than 5 business
days before the effective date of the Registration Statements. It is requested that the Registrants provide a courtesy notification to
the Staff upon EDGAR acceptance of the correspondence.
3. Please make sure the response includes the marked disclosure changes that
the Registrant intends to make by either including specific pages of the Registration Statement with the Correspondence or by clearly
indicating the revised disclosure in the Correspondence.
4. Please note that where a comment is made in one section such comment should
be addressed in all other sections where it applies in the Registration Statements.
5. Please update the tickers for the Funds’ Class A2 Shares when available
in the EDGAR system.
RESPONSE:
The Registrants will respond as requested.
Prospectus Summary Sections and Certain
Statutory Prospectus Sections
COMMENT 2. Prospectus - Risk/Return Summary:
Fees and Expenses
In the first paragraph of the narrative disclosure
preceding the table, please bold the second sentence as required by Item 3 of Form N-1A.
RESPONSE:
The Registrants will respond as requested.
COMMENT 3. Prospectus - Risk/Return Summary:
Fees and Expenses
Please delete Footnote 1 since the shareholder
services/account administration fees disclosed are not currently charged by the Funds. This footnote is not permitted by Item 3 of Form
N-1A.
RESPONSE:
The Registrant confirms that the shareholder
services/account administration fee (“SSF/AAF”) for each Fund’s Class A2 Shares is a Dormant Fee. While the Dormant
Fee has been approved by each Fund’s Board of Trustees (each a “Board”), this Dormant Fee will not be incurred or charged
unless and until they are approved to be activated by the Boards, including a majority of the Independent Trustees, and followed by appropriate
notification to shareholders, including (as necessary) a supplement to the prospectus fee table of the respective Fund.
Respectfully, the Registrant believes that the
presentation of the Dormant Fee in the respective footnotes is consistent with Instruction 3(d)(i) to Item 3 of Form N-1A and is material
information for each Fund’s investors. The Funds do not, and cannot, include the Dormant Fee in the fee table itself.
However, in fairness to investors, each Registrant
believes that it is important to identify in a footnote: (1) the Dormant Fee has been approved by each Board, (2) the maximum allowable
fee amount, as applicable, and (3) disclosure that the Dormant Fee is not currently being charged and will not be incurred or charged
until approved to be activated by a Fund’s Board. Therefore, each Registrant respectfully declines to make any changes in response
to this comment.
COMMENT 4. Prospectus - Risk/Return Summary:
Fees and Expenses
We note Footnote 2 to each Fund’s fee table
regarding estimated expenses. Supplementally, please explain the basis for estimating Other Expenses, which should be based on actual
fund expenses. Is there an expense component that is unique to the new Class A2 Shares?
RESPONSE:
The Registrant confirms that “Other Expenses”
for the new Class A2 Shares are estimated, based, in part, on the current fiscal year expense estimates for each Fund. These estimates
are further adjusted for any additional estimated expenses in connection with the operation of a new share class, which are primarily
based on each Registrant’s projections regarding changes in asset levels related to the new share class.
Therefore, since the “Other Expenses”
listed in the fee table are based on estimated amounts, the Registrant respectfully believes that the inclusion of the footnote as written
is accurate, appropriate and in accordance with Form N-1A requirements.
COMMENT 5. Prospectus - Risk/Return Summary:
Fees and Expenses
In Footnote 3 to each Fund’s fee table,
please remove the references to “on their own initiative” and “voluntary” in the context of waivers and/or reimbursements
in order to avoid shareholder confusion.
RESPONSE:
Each Fund’s investment adviser (collectively,
the “Advisers”) and certain of their affiliates have, voluntarily and on their own initiative, committed to waive certain
amounts of their respective fees and/or reimburse expenses and entered into these agreements with each Fund’s Board unless or until
each Fund’s Board approves terminating or increasing the waivers, thus creating an agreed rate that must be maintained for a year
unless a change is approved by the Board. Each Fund’s Fee Limit, as defined in Footnote 3, is the threshold for total fund operating
expenses under each Fund’s fee waiver and/or expense reimbursement arrangements. Please note that, from time to time, there may
be additional voluntary waivers, over and above the one-year committed waiver, but that those are not permitted to be reflected in the
fee table per Form N-1A. Therefore, the Registrants respectfully decline to make changes to the disclosure regarding voluntary waivers
and reimbursements.
COMMENT 6. Prospectus - Risk/Return Summary:
What are the Fund’s Main Investment Strategies? (Federated Hermes Short-Term Income Fund only)
We note the following disclosure in the first
paragraph:
“The Fund may invest in derivative
contracts to implement its investment strategies.”
Please specify the derivatives in which the Fund
will invest and tailor the related securities and risk disclosures accordingly.
RESPONSE:
The Registrant will revise the above sentence
as follows (additions bold and underlined):
“The Fund may invest in derivative
contracts, in particular, futures contracts, option contracts and swap contracts, to implement its investment strategies.”
In addition, the Registrant will make a conforming
change to the following sentence in paragraph nine of the full investment strategy (additions bold and underlined):
“The Fund may use derivative
contracts, in particular, futures contracts, option contracts and swap contracts, and/or hybrid instruments to increase
or decrease the portfolio’s exposure to the investment(s) underlying the derivative or hybrid.”
The Registrant notes that futures contracts,
option contracts and swap contracts are fully described in the section “What are the Fund’s Principal Investments?”
The risks of the Fund’s investments in derivatives and hybrid instruments are fully described in “Risk of Investing in Derivative
Contracts and Hybrid Instruments” in the section “What are the Specific Risks of Investing in the Fund?”
COMMENT 7. Prospectus - Risk/Return Summary:
What are the Main (or Principal) Risks of Investing in the Fund? (Federated Hermes Short-Intermediate Municipal Fund only)
We note that “Sector Risk” is disclosed.
Please disclose the specific risks of the specific sectors to which the Fund has significant exposure.
RESPONSE:
The Registrant notes that the Fund’s investment
strategy discloses that the “Adviser may also allocate investments in sectors of the tax-exempt market that offer the highest return.”
In addition, the strategy states that “[f]or example, the Fund may use derivative contracts or hybrid instruments to increase or
decrease the portfolio’s exposure to the investment(s) underlying the derivative or hybrid instrument in an attempt to benefit from
changes in the value of the underlying instrument(s) or to gain exposure to the municipal bond sector.”
The sector in which the Fund principally invests
is the tax-exempt or municipal bond sector. The Fund’s Prospectus discloses “Tax-Exempt Securities Risk” in support
of this strategy. In addition, the Fund’s “Sector Risk” additionally provides that a “substantial part of the
Fund’s portfolio may be comprised of securities issued or credit enhanced by companies in similar businesses, or with other similar
characteristics. As a result, the Fund will be more susceptible to any economic, business, political or other developments which generally
affect these issuers or entities.”
Therefore, the Registrant respectfully believes
that its strategy and supporting risk disclosures are appropriate and accurate and that no further revisions are required.
COMMENT 8. Prospectus - Risk/Return Summary:
Performance Bar Chart and Table
We note the footnote to each Fund’s Bar
Chart, which provides each Fund’s Class A Share returns for the six-month period from January 1, 2021 to June 30, 2021. Please update
these returns to include the calendar quarter ended September 30, 2021.
RESPONSE:
The Registrants will update the returns in each
Registrant’s Rule 485(b) filing.
COMMENT 9. Prospectus - Risk/Return Summary:
Average Annual Total Return Table
We note the disclosure in the introductory paragraph of each Fund’s
Average Annual Total Return Table that the A2 Class performance information shown is for each Fund’s A Class as described in the
narrative related to each Fund’s Bar Chart. For clarity, in the first paragraph before the table, please consider removing the reference
to the A2 class in the second sentence, “The A2 class performance information shown below is for the Fund’s A class as described
above.”
Instead, please add a footnote to the Average
Annual Total Return Tables to explain that the returns are for a class that is not presented and which class would have substantially
similar annual returns because the shares are invested in the same portfolio of securities and that the annual returns would differ only
to the extent that the classes do not have the same expenses. If the new class is more expensive than the class shown, state that because
the new class has higher expenses, the new class performance will be lower than the class shown.
RESPONSE:
To address these comments, the reference to A2
will be removed in the second sentence as recommended. Instruction 3(b) to Item 4(b)(2) of Form N-1A only requires the explanation that
the returns are for a class that is not presented that would have substantially similar annual returns to be included with the bar chart.
With respect to the Average Annual Total Return Table, Instruction 3(b) simply instructs registrants to “[i]nclude return information
for the other Class reflected in the bar chart in the performance table.” Accordingly, we respectfully decline to repeat this explanation
in the introduction to the average annual total return table, and we also respectfully decline to add a footnote to state that the returns
would be substantially similar between the classes since it is clearly noted in the introductory Bar Chart paragraph which is referenced.
The Registrants confirm that there are no differences
in the net operating expenses between the A2 class and the A class for each of the Funds. Therefore, an additional sentence will be added
to the AATR introductory paragraph to inform a shareholder that the anticipated difference in total returns between the classes would
be due to differences in sales loads. The paragraph will be disclosed as follows (deletions stricken and additions bold and underlined):
The
Fund’s A2 class is expected to commence operations on or about November 17, 2021. The A2 class performance
information shown below is for the Fund’s A class as described above. It
is anticipated that the sales load of the A2 class will be higher than the sales
load of the A class; accordingly, the net performance of the A2 class is anticipated to be lower than the net performance of the A class.
COMMENT 10. Prospectus - Risk/Return Summary:
Performance Bar Chart and Table
The Staff notes the inclusion of additional comparative
indexes and averages for the Funds in the Average Annual Total Return Table. Form N-1A Item 4(b)(2), Instruction 2.(b), requires disclosure
about one or more other indexes to be included in the narrative explanation accompanying the bar chart and table.
RESPONSE:
In response to the comment, the Registrants note
that Form N-1A Item 4(b)(2), Instruction 2.(b), requires that a fund “disclose information about the additional index in the narrative
explanation accompanying the bar chart and table.” The Registrant notes that its disclosure currently states that the “Average
Annual Total Return Table shows returns averaged over the stated period, and includes comparative performance information.”
In addition, the narrative explanation accompanying
the bar chart and table currently includes footnotes regarding each Fund’s comparative Lipper average.
The Registrants believe that, when taken together,
the above disclosures satisfy the requirements of Form N-1A. Accordingly, the Registrants respectfully decline to revise the disclosure
in response to this comment.
COMMENT 11: Prospectus - “What are the
Fund’s Principal Investments?”
The Staff notes the Asset Segregation disclosure
in each Fund’s Prospectus. Please consider updating this disclosure to discuss the adoption of Rule 18f-4 under the Investment Company
Act of 1940 (the “1940 Act”).
RESPONSE:
In response to the Staff’s comment, the
Registrants note that, on a complex-wide basis, Federated Hermes is continuing to assess the impact the adoption of Rule 18f-4 will have
on the Federated Hermes funds. Accordingly, as the August 2022 compliance date for Rule 18f-4 nears, the Registrants will seek to implement
the Rule and continue to review their disclosure, as part of a Federated Hermes complex-wide effort, in order to determine whether additional
disclosure regarding the impact of Rule 18f-4 and its requirements would be appropriate.
COMMENT 12: Prospectus - “What Do Shares
Cost? Additional Information on the Availability of Certain Waivers and Discounts”
We note the following sentence in the subsection
entitled “Additional Information on the Availability of Certain Waivers and Discounts”:
“The information contained in
Appendix B is based on information provided by these financial intermediaries.”
Please delete this sentence. The Funds cannot
disclaim responsibility for their sales charge waivers and discounts disclosures. Under the 1940 Act, sales loads are set by funds, not
by intermediaries.
RESPONSE:
The Registrants respectfully believe that the
disclosure is accurate. However, in light of the Staff’s comment, the Registrants will make the follo