Correspondence 0001137439-25-000233 from IVY FUNDS (CIK 0000883622)
IVY FUNDS (CIK 0000883622)
Date: March 21, 2025 · CIK: 0000883622 · Accession: 0001137439-25-000233
AI Filing Summary & Sentiment
File numbers found in text: 333-284919, 811-06569
Letter
Attention: Mr. Alberto Zapata and Mr. Tony Burak Ivy Funds (Registrant) File No. 333-284919 File No. 811-06569 Registration Statement on Form N-14 and Request for Acceleration
Dear Mr. Zapata and Mr. Burak:
The above referenced Registration Statement on Form N-14, which was filed on February 13, 2025 (the “Registration Statement”), was filed with the Securities and Exchange Commission pursuant to the Securities Act of 1933, as amended, for the purpose of registering Class A, Class C, Class R6, Class Y and Institutional Class shares of Macquarie Balanced Fund, a series of the Registrant (the “Acquiring Fund”) that will be issued to shareholders of Macquarie Multi-Asset Income Fund, a series of the Registrant (the “Acquired Fund”) in connection with the transfer of substantially all of the assets of the Acquired Fund to the Acquiring Fund, pursuant to an Agreement and Plan of Reorganization, a form of which was included in the Registration Statement.
On behalf of the above referenced Registrant and its principal underwriter, Delaware Distributors, L.P., and pursuant to the requirements of Rule 461 under the Securities Act of 1933, we respectfully request that the effectiveness of the Registrant’s Registration Statement on Form N-14 be accelerated to March 24, 2025, or as soon as practicable thereafter. A definitive Prospectus/Proxy Statement will be filed and mailed to Acquired Fund shareholders shortly thereafter. It is our understanding that you have previously discussed the possible acceleration of the Registration Statement with Taylor Brody of Stradley Ronon Stevens & Young, LLP.
Please contact Taylor Brody at (215) 564-8071 or Jonathan Kopcsik at (215) 564-8099 if you have any questions or comments regarding this filing or the acceleration request.
Sincerely,
/s/ Shawn K. Lytle
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CORRESP
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Ivy Funds
100 Independence, 610 Market Street
Philadelphia, Pennsylvania 19106-2354
Delaware Distributors, L.P.
100 Independence, 610 Market Street
Philadelphia, Pennsylvania 19106-2354
March 21, 2025
Filing Desk
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attention: Mr. Alberto Zapata and Mr. Tony Burak
Re:
Ivy Funds (Registrant)
File No. 333-284919
File No. 811-06569
Registration Statement on Form N-14 and Request for Acceleration
Dear Mr. Zapata and Mr. Burak:
The above referenced Registration Statement on Form N-14, which was filed on February 13, 2025 (the “Registration Statement”), was filed with the Securities and Exchange Commission pursuant to the Securities Act of 1933,
as amended, for the purpose of registering Class A, Class C, Class R6, Class Y and Institutional Class shares of Macquarie Balanced Fund, a series of the Registrant (the “Acquiring Fund”) that will be issued to shareholders of Macquarie Multi-Asset
Income Fund, a series of the Registrant (the “Acquired Fund”) in connection with the transfer of substantially all of the assets of the Acquired Fund to the Acquiring Fund, pursuant to an Agreement and Plan of Reorganization, a form of which was
included in the Registration Statement.
On behalf of the above referenced Registrant and its principal underwriter, Delaware Distributors, L.P., and pursuant to the requirements of Rule 461 under the Securities Act of 1933, we respectfully request that the
effectiveness of the Registrant’s Registration Statement on Form N-14 be accelerated to March 24, 2025, or as soon as practicable thereafter. A definitive Prospectus/Proxy Statement will be filed and mailed to Acquired Fund shareholders shortly
thereafter. It is our understanding that you have previously discussed the possible acceleration of the Registration Statement with Taylor Brody of Stradley Ronon Stevens & Young, LLP.
Please contact Taylor Brody at (215) 564-8071 or Jonathan Kopcsik at (215) 564-8099 if you have any questions or comments regarding this filing or the acceleration request.
Sincerely,
/s/ Shawn K. Lytle
/s/ Richard Salus
Name:
Shawn K. Lytle
Name:
Richard Salus
Title:
President/Chief Executive Officer
Title:
Senior Vice President
Ivy Funds
Delaware Distributors, L.P.