SEC Company Response from ELLSWORTH GROWTH & INCOME FUND LTD (ECF, ECF-PA) (CIK 0000793040) (ECF) — Apr 28, 2021
ELLSWORTH GROWTH & INCOME FUND LTD (ECF, ECF-PA) (CIK 0000793040)
Date: April 28, 2021 · CIK: 0000793040 · Accession: 0001193125-21-137171
AI Filing Summary & Sentiment
File numbers found in text: 811-04656, 811-21698
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission Washington, DC RE: GAMCO Global Gold, Natural Resources & Income Trust (811-21698); Ellsworth Growth & Income Fund Ltd. (811-04656)
Dear Ms. Rotter:
Thank you for your oral comments provided on April 23, 2021, regarding your review of the registration statement on Form N-2 filed on April 8, 2021 (the “Registration Statement”) by GAMCO Global Gold, Natural Resources & Income Trust (“GGN”) with the U.S. Securities and Exchange Commission and your Sarbanes-Oxley review of the 2020 annual reports (the “Annual Reports”) of GGN and Ellsworth Growth & Income Fund Ltd. (“ECF”, and together with GGN, the “Funds”). The Funds have considered your comments and authorized us to respond on their behalf as set forth below. Your oral comments are summarized in bold to the best of our understanding, followed by the Funds’ respective responses. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the applicable Annual Reports.
* * * * * * *
Ms. Mindy Rotter
April 28, 2021
Page 2
Comments and Responses
GGN Registration Statement
1. In the fee table, please confirm in correspondence that the fees presented represent current fees.
The Fund confirms.
Sarbanes-Oxley Review of Annual Reports
2. For ECF, please confirm in correspondence that there are no components of other accrued expenses that should be separately classified on the Statements of Assets and Liabilities.
The Fund confirms.
3. For both Funds, please confirm in correspondence that there are no amounts payable to trustees that need to be disclosed or explain why such amounts have not been stated separately on the statement of assets and liabilities in compliance with Regulation S-X, Rule 6-04.
The Funds confirm.
* * * * * * *
Should you have any additional comments or concerns, please do not hesitate to contact me at (617) 573-4836 or Tom DeCapo at (617) 573-4814.
Best regards,
/s/ Kenneth E. Burdon
Show Raw Text
CORRESP 1 filename1.htm Ellsworth Growth & Income Fund Ltd SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP 500 BOYLSTON STREET BOSTON, MASSACHUSETTS 02116 DIRECT DIAL 617-573-4836 DIRECT FAX 617-305-4836 EMAIL ADDRESS KENNETH.BURDON@SKADDEN.COM ______ TEL: (617) 573-4800 FAX: (617) 573-4822 www.skadden.com FIRM/AFFILIATE OFFICES ----------- CHICAGO HOUSTON LOS ANGELES NEW YORK PALO ALTO WASHINGTON, D.C. WILMINGTON ----------- BEIJING BRUSSELS FRANKFURT HONG KONG LONDON MOSCOW MUNICH PARIS SÃO PAULO SEOUL SHANGHAI SINGAPORE TOKYO TORONTO April 28, 2021 VIA EDGAR Ms. Mindy Rotter Division of Investment Management Securities and Exchange Commission 100 F Street N.E. Washington, DC 20549 RE: GAMCO Global Gold, Natural Resources & Income Trust (811-21698); Ellsworth Growth & Income Fund Ltd. (811-04656) Dear Ms. Rotter: Thank you for your oral comments provided on April 23, 2021, regarding your review of the registration statement on Form N-2 filed on April 8, 2021 (the “Registration Statement”) by GAMCO Global Gold, Natural Resources & Income Trust (“GGN”) with the U.S. Securities and Exchange Commission and your Sarbanes-Oxley review of the 2020 annual reports (the “Annual Reports”) of GGN and Ellsworth Growth & Income Fund Ltd. (“ECF”, and together with GGN, the “Funds”). The Funds have considered your comments and authorized us to respond on their behalf as set forth below. Your oral comments are summarized in bold to the best of our understanding, followed by the Funds’ respective responses. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the applicable Annual Reports. * * * * * * * Ms. Mindy Rotter April 28, 2021 Page 2 Comments and Responses GGN Registration Statement 1. In the fee table, please confirm in correspondence that the fees presented represent current fees. The Fund confirms. Sarbanes-Oxley Review of Annual Reports 2. For ECF, please confirm in correspondence that there are no components of other accrued expenses that should be separately classified on the Statements of Assets and Liabilities. The Fund confirms. 3. For both Funds, please confirm in correspondence that there are no amounts payable to trustees that need to be disclosed or explain why such amounts have not been stated separately on the statement of assets and liabilities in compliance with Regulation S-X, Rule 6-04. The Funds confirm. * * * * * * * Should you have any additional comments or concerns, please do not hesitate to contact me at (617) 573-4836 or Tom DeCapo at (617) 573-4814. Best regards, /s/ Kenneth E. Burdon Kenneth E. Burdon