Correspondence 0001193125-23-139118 from NUVEEN INVESTMENT FUNDS INC (CIK 0000820892)
NUVEEN INVESTMENT FUNDS INC (CIK 0000820892)
Date: May 9, 2023 · CIK: 0000820892 · Accession: 0001193125-23-139118
AI Filing Summary & Sentiment
File numbers found in text: 811-05235, 811-05238, 811-05309, 811-06265, 811-06385, 811-06548, 811-06623, 811-06624, 811-07056, 811-07278, 811-07755, 811-09135, 811-09161, 811-09455, 811-10491, 811-21211, 811-21212, 811-21619, 811-21809, 811-21979, 811-22003, 811-22329, 811-22391, 811-22658, 811-22970, 811-22971, 811-22988, 811-23627
Letter
VIA EDGAR CORRESPONDENCE United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 (File numbers listed in Exhibit A)
Re: SOX Review for Nuveen Fund Advisors, LLC
Dear Ms. Miller:
This letter responds to comments provided by the staff of the Securities and Exchange Commission (the “Staff”) via telephone, pursuant to Section 408 of the Sarbanes-Oxley Act of 2002, regarding the funds advised by Nuveen Fund Advisors, LLC (the “Adviser”) listed in Exhibit A attached hereto (each, a “Fund” and collectively, the “Funds”). Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Funds’ Annual Reports for their respective fiscal years (each, an “Annual Report” and collectively, the “Annual Reports”) as filed on Form N-CSR with the Staff.
COMMENT 1
With regard to the Trustees’ fees for the Nuveen Municipal Bond Funds (i.e., California, Massachusetts, New Jersey and New York) of the Nuveen Multistate Trust II, please explain why the amounts that are shown as the liability on the balance sheet are in excess of what was accrued for the current year on the Statement of Operations. Please include the frequency of payments to Trustees in the Adviser’s response.
RESPONSE TO COMMENT 1
The liability for Trustees fees on the Statement of Assets and Liabilities for the Funds also include deferred compensation amounts that have not yet been paid to Trustees, while the accrued expenses on the Statement of Operations only include those expenses incurred during the reporting period. The liabilities will not be relieved until payment has been made to the Trustees. The Funds make cash payments to the Trustees quarterly, while the deferred compensation payments are dependent on the elections of the individual Trustees.
COMMENT 2
The Staff notes that certain of the Funds have a monthly distribution policy or practice of maintaining a specified level of distribution and paid a return of capital. On a prospective basis, please include a discussion of these events to which the Funds’ distribution policy resulted in distributions of capital or impacted its investment strategies and/or net asset value (see Instruction 4(g)(3) to Item 24 of Form N-2 and Item 27 to Form N-1A).
RESPONSE TO COMMENT 2
On a prospective basis, disclosure will be added to the Common Share Information section of the reports for those Funds that have a policy of maintaining a specified level of distribution. The following are two examples of how such disclosure will appear in the reports, where applicable:
Example 1: Distribution Program
The [each] Fund makes regular cash distributions to shareholders of a stated dollar amount per share. Subject to approval and oversight by the Board of Trustees, the [each] Fund seeks to provide a stable, but not guaranteed, cash flow, independent of the amount of income earned or capital gains realized by the fund. The practice of maintaining a stable distribution level had no material effect on the [each] Fund’s investment strategy during the most recent fiscal year and is not expected to have such an effect in future periods, however, distributions in excess of Fund returns will cause its NAV per share to erode. For additional information, refer to the distribution information section below and in the Notes to Financial Statements herein.
Example 2: Distribution Program
The [each] Fund makes regular cash distributions to shareholders of a stated dollar amount per share. Subject to approval and oversight by the Board of Trustees, the [each] Fund seeks to maintain a stable distribution level designed to deliver the long-term return potential of the [each] Fund’s investment strategy through regular distributions (a “Managed Distribution Program”). The practice of maintaining a stable distribution level had no material effect on the [each] Fund’s investment strategy during the most recent fiscal year and is not expected to have such an effect in future periods, however, distributions in excess of Fund returns will cause its NAV per share to erode. For additional information, refer to the distribution information section below and in the Notes to Financial Statements herein.
* * * * * * * *
Please call me at (312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.
Sincerely yours,
CHAPMAN AND CUTLER LLP
Show Raw Text
CORRESP 1 filename1.htm CORRESP [CHAPMAN AND CUTLER LLP LETTERHEAD] May 9, 2023 VIA EDGAR CORRESPONDENCE Megan F. Miller United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: SOX Review for Nuveen Fund Advisors, LLC (File numbers listed in Exhibit A) Dear Ms. Miller: This letter responds to comments provided by the staff of the Securities and Exchange Commission (the “Staff”) via telephone, pursuant to Section 408 of the Sarbanes-Oxley Act of 2002, regarding the funds advised by Nuveen Fund Advisors, LLC (the “Adviser”) listed in Exhibit A attached hereto (each, a “Fund” and collectively, the “Funds”). Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Funds’ Annual Reports for their respective fiscal years (each, an “Annual Report” and collectively, the “Annual Reports”) as filed on Form N-CSR with the Staff. COMMENT 1 With regard to the Trustees’ fees for the Nuveen Municipal Bond Funds (i.e., California, Massachusetts, New Jersey and New York) of the Nuveen Multistate Trust II, please explain why the amounts that are shown as the liability on the balance sheet are in excess of what was accrued for the current year on the Statement of Operations. Please include the frequency of payments to Trustees in the Adviser’s response. RESPONSE TO COMMENT 1 The liability for Trustees fees on the Statement of Assets and Liabilities for the Funds also include deferred compensation amounts that have not yet been paid to Trustees, while the accrued expenses on the Statement of Operations only include those expenses incurred during the reporting period. The liabilities will not be relieved until payment has been made to the Trustees. The Funds make cash payments to the Trustees quarterly, while the deferred compensation payments are dependent on the elections of the individual Trustees. COMMENT 2 The Staff notes that certain of the Funds have a monthly distribution policy or practice of maintaining a specified level of distribution and paid a return of capital. On a prospective basis, please include a discussion of these events to which the Funds’ distribution policy resulted in distributions of capital or impacted its investment strategies and/or net asset value (see Instruction 4(g)(3) to Item 24 of Form N-2 and Item 27 to Form N-1A). RESPONSE TO COMMENT 2 On a prospective basis, disclosure will be added to the Common Share Information section of the reports for those Funds that have a policy of maintaining a specified level of distribution. The following are two examples of how such disclosure will appear in the reports, where applicable: Example 1: Distribution Program The [each] Fund makes regular cash distributions to shareholders of a stated dollar amount per share. Subject to approval and oversight by the Board of Trustees, the [each] Fund seeks to provide a stable, but not guaranteed, cash flow, independent of the amount of income earned or capital gains realized by the fund. The practice of maintaining a stable distribution level had no material effect on the [each] Fund’s investment strategy during the most recent fiscal year and is not expected to have such an effect in future periods, however, distributions in excess of Fund returns will cause its NAV per share to erode. For additional information, refer to the distribution information section below and in the Notes to Financial Statements herein. Example 2: Distribution Program The [each] Fund makes regular cash distributions to shareholders of a stated dollar amount per share. Subject to approval and oversight by the Board of Trustees, the [each] Fund seeks to maintain a stable distribution level designed to deliver the long-term return potential of the [each] Fund’s investment strategy through regular distributions (a “Managed Distribution Program”). The practice of maintaining a stable distribution level had no material effect on the [each] Fund’s investment strategy during the most recent fiscal year and is not expected to have such an effect in future periods, however, distributions in excess of Fund returns will cause its NAV per share to erode. For additional information, refer to the distribution information section below and in the Notes to Financial Statements herein. * * * * * * * * 2 Please call me at (312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters. Sincerely yours, CHAPMAN AND CUTLER LLP By: /s/ Morrison C. Warren Morrison C. Warren 3 EXHIBIT A File # Registrant Name FYE Reviewed 811-06385 NUVEEN OHIO QUALITY MUNICIPAL INCOME FUND 2/28/2022 811-06265 NUVEEN PENNSYLVANIA QUALITY MUNICIPAL INCOME FUND 2/28/2022 811-06623 NUVEEN CALIFORNIA SELECT TAX FREE INCOME PORTFOLIO 3/31/2022 811-22003 Nuveen Core Equity Alpha Fund 12/31/2022 811-09135 NUVEEN NEW YORK QUALITY MUNICIPAL INCOME FUND 2/28/2022 811-22971 Nuveen NASDAQ 100 Dynamic Overwrite Fund 12/31/2022 811-09161 Nuveen California Quality Municipal Income Fund 2/28/2022 811-21212 NUVEEN CALIFORNIA AMT-FREE QUALITY MUNICIPAL INCOME FUND 2/28/2022 811-06548 NUVEEN SELECT TAX FREE INCOME PORTFOLIO 3/31/2022 811-09455 NUVEEN NEW JERSEY QUALITY MUNICIPAL INCOME FUND 2/28/2022 811-05235 NUVEEN CALIFORNIA MUNICIPAL VALUE FUND 2/28/2022 811-21211 NUVEEN NEW YORK AMT-FREE QUALITY MUNICIPAL INCOME FUND 2/28/2022 811-07278 NUVEEN ARIZONA QUALITY MUNICIPAL INCOME FUND 2/28/2022 811-07056 NUVEEN SELECT MATURITIES MUNICIPAL FUND 3/31/2022 811-21809 Nuveen S&P 500 Dynamic Overwrite Fund 12/31/2022 811-22329 Nuveen Mortgage & Income Fund/MA/ 12/31/2022 811-10491 NUVEEN REAL ESTATE INCOME FUND 12/31/2022 811-22988 Nuveen Global High Income Fund 12/31/2022 811-22658 Nuveen Real Asset Income & Growth Fund 12/31/2022 811-22391 Nuveen Taxable Municipal Income Fund 3/31/2022 811-21619 Nuveen S&P 500 BuyWrite Income Fund 12/31/2022 811-06624 NUVEEN NEW YORK SELECT TAX -FREE INCOME PORTFOLIO 3/31/2022 811-22970 Nuveen Dow 30sm Dynamic Overwrite Fund 12/31/2022 811-05238 NUVEEN NEW YORK MUNICIPAL VALUE FUND 2/28/2022 811-07755 NUVEEN MULTISTATE TRUST II /MA/ 2/28/2022 811-07755 NUVEEN MULTISTATE TRUST II /MA/ 2/28/2022 811-05309 NUVEEN INVESTMENT FUNDS INC 12/31/2022 811-21979 Nuveen Investment Trust V 12/31/2022 811-05309 NUVEEN INVESTMENT FUNDS INC 12/31/2022 811-05309 NUVEEN INVESTMENT FUNDS INC 12/31/2022 811-07755 NUVEEN MULTISTATE TRUST II /MA/ 2/28/2022 811-07755 NUVEEN MULTISTATE TRUST II /MA/ 2/28/2022 811-07755 NUVEEN MULTISTATE TRUST II /MA/ 2/28/2022 811-07755 NUVEEN MULTISTATE TRUST II /MA/ 2/28/2022 811-23627 Nuveen Core Plus Impact Fund 12/31/2022 4