SEC Company Response from GABELLI EQUITY TRUST INC (GAB, GAB-PG, GAB-PH, GAB-PK) (CIK 0000794685) (GAB) — Aug 17, 2005
GABELLI EQUITY TRUST INC (GAB, GAB-PG, GAB-PH, GAB-PK) (CIK 0000794685)
Date: Aug. 17, 2005 · CIK: 0000794685 · Accession: 0000950123-05-010074
AI Filing Summary & Sentiment
File numbers found in text: 333-12611, 811-08560
Letter
Re: The Gabelli Equity Trust Inc. Pre-Effective Amendment No. 1 to Registration Statement on Form N-14 Securities Act File No. 333-12611, Investment Company Act File No. 811-08560 Response to Comments --------------------
<PAGE> August 17, 2005
VIA EDGAR ---------
Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549
Ladies and Gentlemen:
On behalf of The Gabelli Equity Trust Inc. (the "Fund"), this letter responds to the comments made by Laura Hatch of the staff of the Securities and Exchange Commission on August 17, 2005 on Pre-Effective Amendment No. 1 (the "Amendment") to the Fund's Registration Statement on Form N-14 under the Securities Act of 1933, as amended, regarding the proposed reorganization of Sterling Capital Corporation ("Sterling Capital") with the Fund (the "Reorganization"). The Amendment was filed on August 17, 2005. The comments, and the Fund's responses, are as follows:
1. Comment: Please confirm that the time period between the mail date of August 26, 2005 and the meeting date of September 12,2005 complies with state law requirements.
Response: New York law, under which Sterling Capital is organized, requires at least ten, but no more than 60, days between mailing date and meeting date, so the time period complies with state law.
2. Comment: Please add to the disclosure on p. 28 under the caption "Information about the Reorganization--Equity Trust Board
Considerations" that the Fund's Board determined that the Reorganization was in the best interests of the Fund's shareholders.
Response: The Amendment states on p. 27 that "the Board of Directors of each Fund, including a majority of the Non-Interested Directors of each Fund, after consideration of the potential benefits of the Reorganization to the shareholders of that Fund, the options available and consequences that could potentially occur without the Reorganization, and the expenses
<PAGE>
Securities and Exchange Commission August 17, 2005 Page 2
expected to be incurred by that Fund in connection with the Reorganization, determined that the proposed Reorganization is in the best interests of each Fund." The requested change will be made on p. 28.
3. Comment: Please state whether there are any future arrangements between the officers and directors of Sterling Capital, the
Scheuer family or Gaymark Associates with the Fund.
Response: We have been advised that there are no such arrangements.
The Fund requests that the Amendment be declared effective as of 4:00 p.m. on August 17, 2005, or as soon as possible thereafter.
Any questions or comments on the Amendment should be directed to the undersigned at (212) 728-8558.
Very truly yours,
/s/ Dianne E. O'Donnell
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August 17, 2005
VIA EDGAR
---------
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: The Gabelli Equity Trust Inc.
Pre-Effective Amendment No. 1 to Registration Statement on Form N-14
Securities Act File No. 333-12611, Investment Company Act
File No. 811-08560
Response to Comments
--------------------
Ladies and Gentlemen:
On behalf of The Gabelli Equity Trust Inc. (the "Fund"), this letter responds to
the comments made by Laura Hatch of the staff of the Securities and Exchange
Commission on August 17, 2005 on Pre-Effective Amendment No. 1 (the "Amendment")
to the Fund's Registration Statement on Form N-14 under the Securities Act of
1933, as amended, regarding the proposed reorganization of Sterling Capital
Corporation ("Sterling Capital") with the Fund (the "Reorganization"). The
Amendment was filed on August 17, 2005. The comments, and the Fund's responses,
are as follows:
1. Comment: Please confirm that the time period between the mail date of August
26, 2005 and the meeting date of September 12,2005 complies with state law
requirements.
Response: New York law, under which Sterling Capital is organized,
requires at least ten, but no more than 60, days between mailing date and
meeting date, so the time period complies with state law.
2. Comment: Please add to the disclosure on p. 28 under the caption
"Information about the Reorganization--Equity Trust Board
Considerations" that the Fund's Board determined that the Reorganization was in
the best interests of the Fund's shareholders.
Response: The Amendment states on p. 27 that "the Board of Directors of
each Fund, including a majority of the Non-Interested Directors of each Fund,
after consideration of the potential benefits of the Reorganization to the
shareholders of that Fund, the options available and consequences that could
potentially occur without the Reorganization, and the expenses
<PAGE>
Securities and Exchange Commission
August 17, 2005
Page 2
expected to be incurred by that Fund in connection with the Reorganization,
determined that the proposed Reorganization is in the best interests of each
Fund." The requested change will be made on p. 28.
3. Comment: Please state whether there are any future arrangements between the
officers and directors of Sterling Capital, the
Scheuer family or Gaymark Associates with the Fund.
Response: We have been advised that there are no such arrangements.
The Fund requests that the Amendment be declared effective as of 4:00 p.m. on
August 17, 2005, or as soon as possible thereafter.
Any questions or comments on the Amendment should be directed to the undersigned
at (212) 728-8558.
Very truly yours,
/s/ Dianne E. O'Donnell
Dianne E. O'Donnell
Enclosures
cc: Laura Hatch, Division of Investment Management, SEC
Daniel Schloendorn, Esq., Willkie Farr & Gallagher LLP
Bruce Alpert, Gabelli Funds, LLC
James McKee, Esq., Gabelli Funds, LLC
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