Correspondence 0001193125-24-263270 from WASATCH FUNDS TRUST (CIK 0000806633)
WASATCH FUNDS TRUST (CIK 0000806633)
Date: Nov. 21, 2024 · CIK: 0000806633 · Accession: 0001193125-24-263270
AI Filing Summary & Sentiment
File numbers found in text: 811-04920
Letter
VIA EDGAR Securities and Exchange Commission 100 F. Street, N.E. Washington, DC 20549 File Nos. 033-10451, 811-04920
Re: Wasatch Funds Trust (“Registrant”)
Dear Ms. Browning:
This letter responds to the comments on Post-Effective Amendment No. 125 to the Registrant’s registration statement on Form N-1A (“PEA 125”) on behalf of the Wasatch International Value Fund filed on EDGAR on September 13, 2024 that were provided to me by telephone on October 21, 2024 and November 15, 2024 by the staff of the Securities and Exchange Commission (the “Staff”).
Prospectus – Fund Summary – Fees and Expenses of the Fund and Examples
1. Staff Comment: If the Fund intends to engage in short sales, please supplementally confirm that any estimated costs of such short sales will be included in “Other Expenses.”
Response: The Registrant confirms that the Fund does not currently intend to engage in short sales. However, if the Fund does engage in short sales it will include any such applicable costs in “Other Expenses”.
2. Staff Comment: Instruction 3(e) of Form N-1A requires that if a Fund has expense reimbursement or fee waiver arrangement for no less than one year from the effective date of the Fund’s registration statement, the Fund is required to disclose the period for which the expense reimbursement or fee waiver arrangement is expected to continue, including the expected termination date, and briefly describe who can terminate the arrangement and under what circumstances. In Footnote 2, please disclose how long the Fund may recoup such expenses.
Response: The Fund may only make repayments to the Advisor for amounts reimbursed if such repayment does not cause the Fund’s expense ratio, after the repayment is taken into account, to exceed both (i) the expense cap in place at the time such amounts were waived; and (ii) the Fund’s current expense cap. This disclosure is currently set forth in the second sentence of Footnote 2.
The Registrant will add the following disclosure after the second sentence of Footnote 2: “Such repayment can be made until the expiration of the current contract, but in no case beyond three years from the date of such waiver or reimbursement by the Advisor.”
3. Staff Comment: Please provide a completed fee table and expense example.
Response: The fee table and expense example is attached as Appendix A to this letter.
Prospectus – Fund Summary – Principal Strategies
4. Staff Comment: Please confirm that the index named in the second paragraph of this section “MSCI AC (All Country) World Ex-USA Index” is the correct name for the index.
Response: Registrant will revise to clarify the referenced index and will revise the second paragraph as follows:
“Under normal market conditions, we will invest the Fund’s net assets primarily in the equity securities, typically common stock, of foreign companies of all market capitalizations, although we expect a significant portion (greater than 5%) of the Fund’s total assets to be invested in companies with market capitalizations of over $5 billion at the time of purchase. The Advisor considers greater than 5% of total assets to be a significant portion. Under normal market conditions, the Fund will invest in securities issued by companies domiciled in at least five of the countries included in the MSCI ACWI ex USA Index, which captures large and mid cap representation across developed market countries (excluding the U.S.) and emerging markets countries. The MSCI ACWI ex USA Index includes companies domiciled in countries around the world, including companies in the Asia region, Europe and the U.K.”
5. Staff Comment: The first sentence of the second paragraph of this section states: “Under normal market conditions, we will invest the Fund’s net assets primarily in the equity securities, typically common stock, of foreign companies of all market capitalizations.” The fourth paragraph of this section states: “The Fund may invest in the equity securities of companies of any size, although we expect a significant portion of the Fund’s assets to be invested in companies with market capitalizations of over $5 billion at the time of purchase.”
The disclosure includes “all market capitalizations” and “companies of any size”. Please consider harmonizing disclosure to not be repetitive.
Response: As noted above, Registrant will consolidate the two sentences into the first sentence of the second paragraph as follows: “Under normal market conditions, we will invest the Fund’s net assets primarily in the equity securities, typically common stock, of foreign companies of all market capitalizations, although we expect a significant portion (greater than 5%) of the Fund’s assets to be invested in companies with market capitalizations of over $5 billion at the time of purchase.”
6. Staff Comment: The fourth paragraph of this section states: “The Fund may invest in the equity securities of companies of any size, although we expect a significant portion of the Fund’s assets to be invested in companies with market capitalizations of over $5 billion at the time of purchase.” Please quantify what “significant portion” of the Fund’s assets means.
Response: Registrant considers a significant portion to be greater than 5% of the Fund’s assets. Registrant believes 5% is a large enough percentage of the portfolio that it, if negatively impacted, is reasonably likely to affect adversely the Fund’s net asset value and total return.
7. Staff Comment: The seventh paragraph of this section states: “The Fund may invest a significant amount of its assets (greater than 5%) in a particular region or market, including Asia and Europe.” Please indicate whether “assets” is gross or net. Please explain why 5% is considered a significant amount.
In addition, the Fund uses the terms “significant portion”, “significant amount” and “large”. Please consider harmonizing terminology.
Response: See Responses 5 and 6, above. Registrant will consistently use the term “significant portion.”
8. Staff Comment: The eighth paragraph of this section states: “The Fund may invest a large percentage of its assets (greater than 5%) in a few sectors, including communication services, consumer discretionary, consumer staples, energy, health care, financials, industrials, information technology, materials, real estate and utilities.” Please include only if such sectors are principal strategies. In addition, please ensure there is a correlating principal risk pursuant to Item 4 of Form N-1A.
Response: The sectors noted are principal strategies. As requested, the Registrant confirms there is a corresponding principal risk for each listed sector.
Prospectus – Fund Summary – Principal Risks
9. Staff Comment: The third paragraph of the “Current Market and Economic Conditions Risk” states: “The economies of the United States and its trading partners, as well as the financial markets generally, may be adversely impacted by trade disputes and other matters. For example, the United States has imposed trade barriers and restrictions on China. In addition, the Chinese government is engaged in a longstanding dispute with Taiwan, continually threatening an invasion. If the political climate between the United States and China does not improve or continues to deteriorate, if China were to attempt invading Taiwan, or if other geopolitical conflicts develop or worsen, economies, markets and individual securities may be adversely affected, and the value of the Fund’s assets may go down.” Please explain why China is highlighted. Please include appropriate disclosure in Item 4 and Item 9 if investing in China is a principal strategy.
Response: Current market and economic conditions risk is a risk that is deemed principal under Item 4 because it is one to which the Fund’s entire portfolio is subject. While direct investment in China is not a principal investment strategy of the Fund, China is a significant trading partner with the United States and has significant influence on Asia and global markets. As noted above, the Fund may invest a significant portion of its assets in the Asia region. Accordingly, Registrant believes for this strategy it is appropriate, in the context of market and economic conditions risk, to explain the global and regional political climate surrounding China and to highlight it as creating a specific potential adverse impact on the Fund’s net asset value and total return.
10. Staff Comment: Please consider re-ordering the principal risks for the Fund in order of significance. For example, Equity Securities Risk, Emerging Markets Risk and Frontier Markets Risk would be prominent.
Response: Registrant will reorder risks by importance (in its view) consistent with the September 2019 Investment Management Staff guidance on principal fund risk disclosure.
11. Staff Comment: The Fund currently has “Asian Region Risk” as a principal risk. Please add correlating Item 4 disclosure to principal strategies.
Response: Investing in the Asia-Pacific was already included in the principal strategy section. However, investing in the Asia region has been highlighted as a principal strategy of the Fund after the revisions outlined in Response 4, above.
12. Staff Comment: The Fund currently has “Large Company Stock Risk” as a principal risk. The first sentence of the second paragraph of the Fund Summary-Principal Strategies section states: “Under normal market conditions, we will invest the Fund’s net assets primarily in the equity securities, typically common stock, of foreign companies of all market capitalizations.” Please add correlating principal risk with respect to investing in all market capitalizations.
Response: Registrant will add a small and mid-cap company stock risk disclosure.
13. Staff Comment: The Fund currently has “Developed Markets Risk” as a principal risk. Please add correlating Item 4 disclosure to principal strategies. If a non-principal risk, please move disclosure to Item 16 in the Fund’s Statement of Additional Information.
Response: See Response 4, above; Investing in developed markets has been highlighted as a principal strategy of the Fund.
14. Staff Comment: Please consider adding a New Fund Risk to the principal risks for the Fund.
Response: Registrant will add the following:
New Fund Risk. Because a new fund begins operations with few assets, operating expenses for a new fund are relatively high until the fund begins to manage sufficient assets to achieve operating efficiencies. While the Advisor has contractually agreed to reimburse Fund expenses over a certain level for a period of time to keep shareholder expenses at a certain specific level, there is a risk that the expense limitation agreement is not continued, and the expenses of the Fund increase significantly until the Fund reaches scale. There is also the risk that the Fund never reaches scale, that the investment strategies do not work as expected and the that the Fund fails to achieve its stated investment objective.
Prospectus – Fund Summary – Historical Performance
15. Staff Comment: Please provide supplementally to the Staff the benchmark that the Fund will use for performance.
Response: As of the date of this response, the Fund intends to use the MSCI World Ex USA Value Index as the Fund’s performance benchmark and the MSCI World Ex USA Index as the broad-based benchmark.
Prospectus – Fund Summary – Portfolio Management – Portfolio Managers
16. Staff Comment: Item 5(b) of Form N-1A states that for Portfolio Manager(s). State the name, title, and length of service of the person or persons employed by or associated with the Fund or an investment adviser of the Fund who are primarily responsible for the day-to-day
management of the Fund’s portfolio (“Portfolio Manager”). Instruction 2 of Item 5 of Form N-1A states that if a committee, team, or other group of persons associated with the Fund or an investment adviser of the Fund is jointly and primarily responsible for the day-to-day management of the Fund’s portfolio, information in response to this Item is required for each member of such committee, team, or other group.
The current disclosure in the prospectus is set forth below.
David Powers, CFA
Lead Portfolio Manager
Since the Fund’s Inception
Nakul Chaturvedi
Associate Portfolio Manager
Since the Fund’s Inception
Please clarify length of service for each portfolio manager. In addition, pursuant to Instruction 2 of Item 5 of Form N-1A states that if a committee, team, or other group of persons associated with the Fund or an investment adviser of the Fund is jointly and primarily responsible for the day-to-day management of the Fund’s portfolio, information in response to this Item is required for each member of such committee, team, or other group.
Response: The length of service disclosure required under Item 5(b) of Form N-1A is with respect to the Fund. Accordingly, the disclosure reflects that each portfolio manager for the Fund has served in this position since the Fund’s inception. In addition, each portfolio manager’s business experience during the past five years, including his/her length of service with the advisor, is included in the “Portfolio Managers” section of the prospectus as required by Item 10(a)(2) of Form N-1A.
Prospectus – Additional Information about the Fund – Additional Information about Investment Strategies and Risks
17. Staff Comment: Please consider revising this Item 9 disclosure to remove any duplicative disclosure that is already included in Item 4 of the Summary section of the Prospectus. Please revise this disclosure as Item 4 should be a summary of principal strategies and principal risks and Item 9 should be a more complete discussion of the Fund’s principal strategies and principal risks.
Response: The Registrant believes that the current prospectus already appropriately distinguishes between principal and non-principal strategies and risks. Consistent with Item 9(c) and Item 4 of Form N-1A, the Fund discloses the principal strategies and principal risks of investing in the Fund in the summary “Risk/Return Summary” section. The information in the section entitled “Additional Information about the Fund - Investment Strategies and Risks” supplements the principal risk disclosure in the summaries and also provides information regarding certain non-principal strategies and risks but identifies whether the strategy is a principal or non-principal risk to the Fund.
The Registrant acknowledges that the Staff objects to the Registrant keeping non-principal investment strategies in this section and that the Staff believes such disclosure should be moved to the Fund’s Statement of Additional Information.
18. Staff Comment: Please relocate any non-principal investment strategies to the Statement of Additional Information. Item 9 disclosure should be related to further description of the Fund’s principal investment strategies. Please see Instruction 2 to Item 9(b) of Form N-1A and IM Guidance Update No. 2014-08.
Response: Although Item 9 requires the Fund to describe its principal investment strategies, general instruction C(3)(b) provides that a Fund may include information in the prospectus that is not otherwise required. In IM Guidance Update No. 2014-08, the staff recognized that in this regard, many funds include in their prospectus additional information related to strategies and risks that are not principal. To avoid ambiguity as to strategies and risks that are principal and those that are non-principal, the staff noted that the staff would comment that funds should distinguish which of the strategies and risks are principal and which are not principal. The information in the section entitled “Additional Information about the Fund - Inve
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CORRESP 1 filename1.htm CORRESP VIA EDGAR November 21, 2024 Ms. Kimberly Browning Securities and Exchange Commission Investment Company Division 100 F. Street, N.E. Washington, DC 20549 Re: Wasatch Funds Trust (“Registrant”) File Nos. 033-10451, 811-04920 Dear Ms. Browning: This letter responds to the comments on Post-Effective Amendment No. 125 to the Registrant’s registration statement on Form N-1A (“PEA 125”) on behalf of the Wasatch International Value Fund filed on EDGAR on September 13, 2024 that were provided to me by telephone on October 21, 2024 and November 15, 2024 by the staff of the Securities and Exchange Commission (the “Staff”). Prospectus – Fund Summary – Fees and Expenses of the Fund and Examples 1. Staff Comment: If the Fund intends to engage in short sales, please supplementally confirm that any estimated costs of such short sales will be included in “Other Expenses.” Response: The Registrant confirms that the Fund does not currently intend to engage in short sales. However, if the Fund does engage in short sales it will include any such applicable costs in “Other Expenses”. 2. Staff Comment: Instruction 3(e) of Form N-1A requires that if a Fund has expense reimbursement or fee waiver arrangement for no less than one year from the effective date of the Fund’s registration statement, the Fund is required to disclose the period for which the expense reimbursement or fee waiver arrangement is expected to continue, including the expected termination date, and briefly describe who can terminate the arrangement and under what circumstances. In Footnote 2, please disclose how long the Fund may recoup such expenses. Response: The Fund may only make repayments to the Advisor for amounts reimbursed if such repayment does not cause the Fund’s expense ratio, after the repayment is taken into account, to exceed both (i) the expense cap in place at the time such amounts were waived; and (ii) the Fund’s current expense cap. This disclosure is currently set forth in the second sentence of Footnote 2. The Registrant will add the following disclosure after the second sentence of Footnote 2: “Such repayment can be made until the expiration of the current contract, but in no case beyond three years from the date of such waiver or reimbursement by the Advisor.” 1 3. Staff Comment: Please provide a completed fee table and expense example. Response: The fee table and expense example is attached as Appendix A to this letter. Prospectus – Fund Summary – Principal Strategies 4. Staff Comment: Please confirm that the index named in the second paragraph of this section “MSCI AC (All Country) World Ex-USA Index” is the correct name for the index. Response: Registrant will revise to clarify the referenced index and will revise the second paragraph as follows: “Under normal market conditions, we will invest the Fund’s net assets primarily in the equity securities, typically common stock, of foreign companies of all market capitalizations, although we expect a significant portion (greater than 5%) of the Fund’s total assets to be invested in companies with market capitalizations of over $5 billion at the time of purchase. The Advisor considers greater than 5% of total assets to be a significant portion. Under normal market conditions, the Fund will invest in securities issued by companies domiciled in at least five of the countries included in the MSCI ACWI ex USA Index, which captures large and mid cap representation across developed market countries (excluding the U.S.) and emerging markets countries. The MSCI ACWI ex USA Index includes companies domiciled in countries around the world, including companies in the Asia region, Europe and the U.K.” 5. Staff Comment: The first sentence of the second paragraph of this section states: “Under normal market conditions, we will invest the Fund’s net assets primarily in the equity securities, typically common stock, of foreign companies of all market capitalizations.” The fourth paragraph of this section states: “The Fund may invest in the equity securities of companies of any size, although we expect a significant portion of the Fund’s assets to be invested in companies with market capitalizations of over $5 billion at the time of purchase.” The disclosure includes “all market capitalizations” and “companies of any size”. Please consider harmonizing disclosure to not be repetitive. Response: As noted above, Registrant will consolidate the two sentences into the first sentence of the second paragraph as follows: “Under normal market conditions, we will invest the Fund’s net assets primarily in the equity securities, typically common stock, of foreign companies of all market capitalizations, although we expect a significant portion (greater than 5%) of the Fund’s assets to be invested in companies with market capitalizations of over $5 billion at the time of purchase.” 6. Staff Comment: The fourth paragraph of this section states: “The Fund may invest in the equity securities of companies of any size, although we expect a significant portion of the Fund’s assets to be invested in companies with market capitalizations of over $5 billion at the time of purchase.” Please quantify what “significant portion” of the Fund’s assets means. Response: Registrant considers a significant portion to be greater than 5% of the Fund’s assets. Registrant believes 5% is a large enough percentage of the portfolio that it, if negatively impacted, is reasonably likely to affect adversely the Fund’s net asset value and total return. 2 7. Staff Comment: The seventh paragraph of this section states: “The Fund may invest a significant amount of its assets (greater than 5%) in a particular region or market, including Asia and Europe.” Please indicate whether “assets” is gross or net. Please explain why 5% is considered a significant amount. In addition, the Fund uses the terms “significant portion”, “significant amount” and “large”. Please consider harmonizing terminology. Response: See Responses 5 and 6, above. Registrant will consistently use the term “significant portion.” 8. Staff Comment: The eighth paragraph of this section states: “The Fund may invest a large percentage of its assets (greater than 5%) in a few sectors, including communication services, consumer discretionary, consumer staples, energy, health care, financials, industrials, information technology, materials, real estate and utilities.” Please include only if such sectors are principal strategies. In addition, please ensure there is a correlating principal risk pursuant to Item 4 of Form N-1A. Response: The sectors noted are principal strategies. As requested, the Registrant confirms there is a corresponding principal risk for each listed sector. Prospectus – Fund Summary – Principal Risks 9. Staff Comment: The third paragraph of the “Current Market and Economic Conditions Risk” states: “The economies of the United States and its trading partners, as well as the financial markets generally, may be adversely impacted by trade disputes and other matters. For example, the United States has imposed trade barriers and restrictions on China. In addition, the Chinese government is engaged in a longstanding dispute with Taiwan, continually threatening an invasion. If the political climate between the United States and China does not improve or continues to deteriorate, if China were to attempt invading Taiwan, or if other geopolitical conflicts develop or worsen, economies, markets and individual securities may be adversely affected, and the value of the Fund’s assets may go down.” Please explain why China is highlighted. Please include appropriate disclosure in Item 4 and Item 9 if investing in China is a principal strategy. Response: Current market and economic conditions risk is a risk that is deemed principal under Item 4 because it is one to which the Fund’s entire portfolio is subject. While direct investment in China is not a principal investment strategy of the Fund, China is a significant trading partner with the United States and has significant influence on Asia and global markets. As noted above, the Fund may invest a significant portion of its assets in the Asia region. Accordingly, Registrant believes for this strategy it is appropriate, in the context of market and economic conditions risk, to explain the global and regional political climate surrounding China and to highlight it as creating a specific potential adverse impact on the Fund’s net asset value and total return. 10. Staff Comment: Please consider re-ordering the principal risks for the Fund in order of significance. For example, Equity Securities Risk, Emerging Markets Risk and Frontier Markets Risk would be prominent. Response: Registrant will reorder risks by importance (in its view) consistent with the September 2019 Investment Management Staff guidance on principal fund risk disclosure. 3 11. Staff Comment: The Fund currently has “Asian Region Risk” as a principal risk. Please add correlating Item 4 disclosure to principal strategies. Response: Investing in the Asia-Pacific was already included in the principal strategy section. However, investing in the Asia region has been highlighted as a principal strategy of the Fund after the revisions outlined in Response 4, above. 12. Staff Comment: The Fund currently has “Large Company Stock Risk” as a principal risk. The first sentence of the second paragraph of the Fund Summary-Principal Strategies section states: “Under normal market conditions, we will invest the Fund’s net assets primarily in the equity securities, typically common stock, of foreign companies of all market capitalizations.” Please add correlating principal risk with respect to investing in all market capitalizations. Response: Registrant will add a small and mid-cap company stock risk disclosure. 13. Staff Comment: The Fund currently has “Developed Markets Risk” as a principal risk. Please add correlating Item 4 disclosure to principal strategies. If a non-principal risk, please move disclosure to Item 16 in the Fund’s Statement of Additional Information. Response: See Response 4, above; Investing in developed markets has been highlighted as a principal strategy of the Fund. 14. Staff Comment: Please consider adding a New Fund Risk to the principal risks for the Fund. Response: Registrant will add the following: New Fund Risk. Because a new fund begins operations with few assets, operating expenses for a new fund are relatively high until the fund begins to manage sufficient assets to achieve operating efficiencies. While the Advisor has contractually agreed to reimburse Fund expenses over a certain level for a period of time to keep shareholder expenses at a certain specific level, there is a risk that the expense limitation agreement is not continued, and the expenses of the Fund increase significantly until the Fund reaches scale. There is also the risk that the Fund never reaches scale, that the investment strategies do not work as expected and the that the Fund fails to achieve its stated investment objective. Prospectus – Fund Summary – Historical Performance 15. Staff Comment: Please provide supplementally to the Staff the benchmark that the Fund will use for performance. Response: As of the date of this response, the Fund intends to use the MSCI World Ex USA Value Index as the Fund’s performance benchmark and the MSCI World Ex USA Index as the broad-based benchmark. Prospectus – Fund Summary – Portfolio Management – Portfolio Managers 16. Staff Comment: Item 5(b) of Form N-1A states that for Portfolio Manager(s). State the name, title, and length of service of the person or persons employed by or associated with the Fund or an investment adviser of the Fund who are primarily responsible for the day-to-day 4 management of the Fund’s portfolio (“Portfolio Manager”). Instruction 2 of Item 5 of Form N-1A states that if a committee, team, or other group of persons associated with the Fund or an investment adviser of the Fund is jointly and primarily responsible for the day-to-day management of the Fund’s portfolio, information in response to this Item is required for each member of such committee, team, or other group. The current disclosure in the prospectus is set forth below. David Powers, CFA Lead Portfolio Manager Since the Fund’s Inception Nakul Chaturvedi Associate Portfolio Manager Since the Fund’s Inception Please clarify length of service for each portfolio manager. In addition, pursuant to Instruction 2 of Item 5 of Form N-1A states that if a committee, team, or other group of persons associated with the Fund or an investment adviser of the Fund is jointly and primarily responsible for the day-to-day management of the Fund’s portfolio, information in response to this Item is required for each member of such committee, team, or other group. Response: The length of service disclosure required under Item 5(b) of Form N-1A is with respect to the Fund. Accordingly, the disclosure reflects that each portfolio manager for the Fund has served in this position since the Fund’s inception. In addition, each portfolio manager’s business experience during the past five years, including his/her length of service with the advisor, is included in the “Portfolio Managers” section of the prospectus as required by Item 10(a)(2) of Form N-1A. Prospectus – Additional Information about the Fund – Additional Information about Investment Strategies and Risks 17. Staff Comment: Please consider revising this Item 9 disclosure to remove any duplicative disclosure that is already included in Item 4 of the Summary section of the Prospectus. Please revise this disclosure as Item 4 should be a summary of principal strategies and principal risks and Item 9 should be a more complete discussion of the Fund’s principal strategies and principal risks. Response: The Registrant believes that the current prospectus already appropriately distinguishes between principal and non-principal strategies and risks. Consistent with Item 9(c) and Item 4 of Form N-1A, the Fund discloses the principal strategies and principal risks of investing in the Fund in the summary “Risk/Return Summary” section. The information in the section entitled “Additional Information about the Fund - Investment Strategies and Risks” supplements the principal risk disclosure in the summaries and also provides information regarding certain non-principal strategies and risks but identifies whether the strategy is a principal or non-principal risk to the Fund. The Registrant acknowledges that the Staff objects to the Registrant keeping non-principal investment strategies in this section and that the Staff believes such disclosure should be moved to the Fund’s Statement of Additional Information. 18. Staff Comment: Please relocate any non-principal investment strategies to the Statement of Additional Information. Item 9 disclosure should be related to further description of the Fund’s principal investment strategies. Please see Instruction 2 to Item 9(b) of Form N-1A and IM Guidance Update No. 2014-08. 5 Response: Although Item 9 requires the Fund to describe its principal investment strategies, general instruction C(3)(b) provides that a Fund may include information in the prospectus that is not otherwise required. In IM Guidance Update No. 2014-08, the staff recognized that in this regard, many funds include in their prospectus additional information related to strategies and risks that are not principal. To avoid ambiguity as to strategies and risks that are principal and those that are non-principal, the staff noted that the staff would comment that funds should distinguish which of the strategies and risks are principal and which are not principal. The information in the section entitled “Additional Information about the Fund - Inve