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SEC Company Response from Federated Hermes Income Securities Trust (CIK 0000789281) — Dec 16, 2021

Federated Hermes Income Securities Trust (CIK 0000789281)
Date: Dec. 16, 2021 · CIK: 0000789281 · Accession: 0001623632-21-001591

AI Filing Summary & Sentiment

File numbers found in text: 811-4577

Date
December 16, 2021
Author
However, in fairness to investors, the Registrant
Form
CORRESP
Company
Federated Hermes Income Securities Trust (CIK 0000789281)

Letter

Division of Investment Management FEDERATED HERMES INCOME SECURITIES TRUST (the “Registrant”) Federated Hermes Real Return Bond Fund (to be renamed Federated Hermes Inflation Protected Securities Fund) (the “Fund”) 1933 Act File No. 33-3164 1940 Act File No. 811-4577

Dear Mr. Esperon:

The above-named Registrant is filing this correspondence to respond to comments of the Staff of the Securities and Exchange Commission (the “Staff”), provided on December 9, 2021 regarding the Fund’s Rule 485(a) filing submitted on October 25, 2021 as Post-Effective Amendment No. 230 under the Securities Act of 1933, as amended and Amendment No. 223 under the Investment Company Act of 1940, as amended (the “1940 Act”).

COMMENT 1. General Comments

1. The Registrant is responsible for the accuracy and adequacy of its disclosure notwithstanding review by the Staff.

2. The Registrant must file its responses on EDGAR no later than 5 business days before the effective date of the Registration Statement. It is requested that the Registrant 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 Statement.

5. Please update the Fund’s name and its ticker symbol in line with the Fund’s Rule 485(b) filing.

RESPONSE:

The Registrant will respond as requested.

Summary Prospectus

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 Registrant will respond as requested.

COMMENT 3. Prospectus - Risk/Return Summary: Fees and Expenses

Please delete Footnotes 1 and 3 as these footnotes are not permitted by Item 3 of Form N-1A.

RESPONSE:

The Registrant confirms that the distribution (“12b-1 Fee”) fee of the Fund’s Class A Shares and the shareholder services/account administration fee (“SSF/AAF”) of the Fund’s Institutional Shares are approved but currently not charged (“Dormant Fees”). While the Dormant Fees have been approved by the Fund’s Board of Trustees (the “Board”), the Dormant Fees will not be incurred or charged unless and until they are approved to be activated by the Board, 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 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 the Fund’s investors. The Fund does not, and cannot, include the Dormant Fee in the fee table itself.
However, in fairness to investors, the Registrant
believes that it is important to identify in footnotes: (1) that the Dormant Fees have been approved by the Board, (2) the maximum allowable
fee amounts, as applicable, and (3) that the Dormant Fees are not currently being charged and will not be incurred or charged until approved
to be activated by the Fund’s Board. Therefore, the Registrant respectfully declines to make any changes in response to this comment.

Show Raw Text
CORRESP
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filename1.htm

FEDERATED HERMES INCOME SECURITIES TRUST

4000 Ericsson Drive

Warrendale, Pennsylvania 15086-7561

December 16, 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 (the “Registrant”)

    Federated Hermes Real Return Bond Fund (to be renamed Federated Hermes
    Inflation Protected Securities Fund) (the “Fund”)

    1933 Act File No. 33-3164

    1940 Act File No. 811-4577

Dear Mr. Esperon:

The above-named Registrant is filing this correspondence
to respond to comments of the Staff of the Securities and Exchange Commission (the “Staff”), provided on December 9, 2021
regarding the Fund’s Rule 485(a) filing submitted on October 25, 2021 as Post-Effective Amendment No. 230 under the Securities Act
of 1933, as amended and Amendment No. 223 under the Investment Company Act of 1940, as amended (the “1940 Act”).

COMMENT 1. General Comments

 1. The Registrant is responsible for the accuracy and adequacy of its disclosure
notwithstanding review by the Staff.

 2. The Registrant must file its responses on EDGAR no later than 5 business
days before the effective date of the Registration Statement. It is requested that the Registrant 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 Statement.

 5. Please update the Fund’s name and its ticker symbol in line with the
Fund’s Rule 485(b) filing.

RESPONSE:

The Registrant will respond as requested.

Summary Prospectus

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 Registrant will respond as requested.

COMMENT 3. Prospectus - Risk/Return Summary:
Fees and Expenses

Please delete Footnotes 1 and 3 as these footnotes
are not permitted by Item 3 of Form N-1A.

RESPONSE:

The Registrant confirms that the distribution
(“12b-1 Fee”) fee of the Fund’s Class A Shares and the shareholder services/account administration fee (“SSF/AAF”)
of the Fund’s Institutional Shares are approved but currently not charged (“Dormant Fees”). While the Dormant Fees have
been approved by the Fund’s Board of Trustees (the “Board”), the Dormant Fees will not be incurred or charged unless
and until they are approved to be activated by the Board, 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 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 the Fund’s investors. The Fund does not, and cannot, include the Dormant Fee in the fee table itself.

However, in fairness to investors, the Registrant
believes that it is important to identify in footnotes: (1) that the Dormant Fees have been approved by the Board, (2) the maximum allowable
fee amounts, as applicable, and (3) that the Dormant Fees are not currently being charged and will not be incurred or charged until approved
to be activated by the Fund’s Board. Therefore, the 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 in the 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 R6 Shares?

RESPONSE:

The Registrant confirms that “Other Expenses”
for the new Class R6 Shares are estimated, based, in part, on the current fiscal year expense estimates for the 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 the 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. Additionally, the Registrant will ensure that the placement of
the footnote is clear with respect to the Class R6 Shares in the fee table.

COMMENT 5. Prospectus - Risk/Return Summary:
Fees and Expenses

In Footnote 4 to the 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:

The Fund’s investment adviser (the “Adviser”)
and certain of its 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 the Fund’s Board unless or until the 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. The Fund’s Fee Limit, as defined in Footnote 4, is the threshold for total fund operating expenses under the 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 Registrant respectfully declines 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?

We note the following disclosure in the first
paragraph:

“The Fund may invest in derivative
instruments, such as credit default swap agreements, to synthesize inflation-indexed bonds.”

Please specify the types of derivative instruments
that the Fund may use and include corresponding risk disclosure. We note that any principal investment strategies disclosure related to
derivatives should be tailored specifically to how the Fund intends to use them in achieving its objectives. Further, the disclosure concerning
the Fund’s principal risks should similarly be tailored to the types of derivatives used by the Fund, the extent of their use, and
the purpose for using derivative transactions. See the letter from Barry Miller of the Division of Investment Management of the SEC to
the Investment Company Institute dated July 30, 2010.

Additionally, we note that the Item 9 disclosure
differs from the Item 4 summary investment strategy disclosure and they should be aligned.

Please also elaborate on the phrase “to
synthesize inflation-indexed bonds.” What does this mean?

RESPONSE:

The Registrant will tailor the investment strategy
disclosure to note credit default swaps, options and futures contracts as the types of derivatives the Fund may use.

Supplementally, after further consideration and
examination of the Fund’s primary investment strategy and related securities, the Registrant has determined to remove the disclosure
relating to synthesizing inflation-indexed bonds from the Fund.

Accordingly, the Registrant will remove references
to synthesizing inflation-indexed bonds throughout the document and include instead the following derivatives strategy disclosure:

“The Fund may use derivative
contracts to implement elements of its investment strategy, in particular credit default swap agreements, options and futures contracts)
related to conventional bonds.”

In addition, under the Item 9 section “What
are the Fund’s Principal Investments?” the Registrant will add the following disclosure:

“Credit Default Swaps

A credit default swap (CDS) is an
agreement between two parties whereby one party (the “Protection Buyer”) agrees to make payments over the term of the CDS
to the other party (the “Protection Seller”), provided that no designated event of default, restructuring or other credit
related event (each a “Credit Event”) occurs with respect to Reference Instrument that is usually a particular bond, loan
or the unsecured credit of an issuer, in general (the “Reference Obligation”). Many CDS are physically settled, which means
that if a Credit Event occurs, the Protection Seller must pay the Protection Buyer the full notional value, or “par value,”
of the Reference Obligation in exchange for delivery by the Protection Buyer of the Reference Obligation or another similar obligation
issued by the issuer of the Reference Obligation (the “Deliverable Obligation”). The Counterparties agree to the characteristics
of the Deliverable Obligation at the time that they enter into the CDS. Alternately, a CDS can be “cash settled,” which means
that upon the occurrence of a Credit Event, the Protection Buyer will receive a payment from the Protection Seller equal to the difference
between the par amount of the Reference Obligation and its market value at the time of the Credit Event. The Fund may be either the Protection
Buyer or the Protection Seller in a CDS. If the Fund is a Protection Buyer and no Credit Event occurs, the Fund will lose its entire investment
in the CDS (i.e., an amount equal to the payments made to the Protection Seller over the term of the CDS). However, if a Credit Event
occurs, the Fund (as Protection Buyer) will deliver the Deliverable Obligation and receive a payment equal to the full notional value
of the Reference Obligation, even though the Reference Obligation may have little or no value. If the Fund is the Protection Seller and
no Credit Event occurs, the Fund will receive a fixed rate of income throughout the term of the CDS. However, if a Credit Event occurs,
the Fund (as Protection Seller) will pay the Protection Buyer the full notional value of the Reference Obligation and receive the Deliverable
Obligation from the Protection Buyer. A CDS may involve greater risks than if the Fund invested directly in the Reference Obligation.
For example, a CDS may increase credit risk since the Fund has exposure to both the issuer of the Reference Obligation and the Counterparty
to the CDS.”

COMMENT 7. Prospectus - Risk/Return Summary:
What are the Fund’s Main Investment Strategies?

We note the following sentence:

“In addition, the Fund may invest
in high-yield, foreign and non-U.S. dollar inflation-indexed fixed-income securities when the Adviser considers the risk-return prospects
of those sectors to be attractive.”

Please disclose that high-yield investments are
“junk bonds.”

In addition, with respect to the Fund’s
investment in foreign securities, please confirm if the Fund will invest in emerging market securities. If the Fund will invest in emerging
market securities, please disclose this in the Fund’s investment strategy and risk disclosures.

RESPONSE:

The Registrant will make the following revision
(addition bold and underlined):

“In addition, the Fund may invest
in high-yield, foreign and non-U.S. dollar inflation-indexed fixed-income securities when the Adviser considers the risk-return prospects
of those sectors to be attractive. High-yield securities are also known as “junk bonds.”

With respect to the Fund’s investment in foreign securities,
the Registrant confirms that the Fund will not invest in emerging market securities principally. Accordingly, the references to emerging
markets will be removed in “Currency Risk” and “Investing in Securities of Other Investment Companies.”

COMMENT 8. Prospectus - Risk/Return Summary:
What are the Fund’s Main Investment Strategies?

Does the Fund use duration criteria with respect
to its investments? If it does use duration criteria, please disclose this in the Fund’s investment strategy.

In particular, we note the duration disclosure
in “Interest Rate Risk.” If the Fund does not use duration criteria, then please delete the duration disclosure from “Interest
Rate Risk” in the summary and statutory risk sections.

RESPONSE:

The Registrant confirms the Fund uses
duration criteria. The Registrant will move the noted sentence from Interest Rate Risk, as updated below, to the Fund’s investment
strategies (deletion stricken and addition bold and underlined):“It is important to emphasize that the The
Fund operates within a duration range of 0% to 120% of its benchmark.”

COMMENT 9. Prospectus - Risk/Return Summary:
What are the Fund’s Main Investment Strategies?

Please elaborate on the investment adviser’s
strategy for buying and selling securities. Please align the Item 4 strategy disclosure with the Item 9 strategy disclosure.

RESPONSE:

The Registrant will add the below disclosure
to both the Item 4 and Item investment strategies sections.

“The Fund may sell securities
for a variety of reasons such as to secure gains, limit losses or redeploy assets into more promising opportunities.”

COMMENT 10. Prospectus - Risk/Return Summary:
What are the Main Risks of Investing in the Fund?”

With respect to “Risk of Investing in Derivative
Contracts and Hybrid Instruments,” please confirm if the Fund will invest in hybrid instruments. If it will, please add disclosure
on hybrid instruments to the strategy disclosure.

Please disclose the risks related to investing
in credit default swaps.

RESPONSE:

The Registrant believes the current Item 4 and
Item 9 “Risk of Investing in Derivative Instruments” adequately summarizes the principal risks of investing in futures contracts,
options contracts, and credit default swaps and that no additional risk disclosure is necessary.

COMMENT 11. Prospectus - Risk/Return Summary:
Average Annual Total Return Table

Please 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.

RESPONSE:

The Registrant respectfully notes that the returns
are for a class that is presented, as the IS class is included in this prospectus. However, the Registrant will revise the disclosure
as follows (addition bold and underlined):

“The Fund’s R6 class is
anticipated to commence operations on or about January 3, 2022. For the periods prior to commencement of operations of the Fund’s
R6 class, the performance information shown below is for the Fund’s IS class. Returns for the Fund’s R6 class would
have been substantially similar to returns of the Fund’s IS class because each share class is invested in the same portfolio of
securities and returns would differ only to the extent that expenses of the classes are different. The performance of the IS class
has not been adjusted to reflect the expenses applicable to the R6 class since the R6 class is expected to have a lower expense ratio
than the expense ratio of the IS class.”

COMMENT 12. Prospectus - Risk/Return Summary:
Average Annual Total Return Table

The Staff notes the inclusion of an additional
comparative index for the Fund 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:

The Registrant will revise the introductory disclosure
as sh