Correspondence 0001680359-23-000035 from IVY FUNDS (CIK 0000883622)
IVY FUNDS (CIK 0000883622)
Date: Feb. 8, 2023 · CIK: 0000883622 · Accession: 0001680359-23-000035
AI Filing Summary & Sentiment
Letter
Via EDGAR Transmission Division of Investment Management 100 Pearl Street, Suite 20-100 New York, NY 10004-2616 Re: Sarbanes-Oxley Review of Shareholder Reports for Various Delaware Funds by Macquarie® Registrants
Dear Ms. Rotter:
On behalf of each of the Delaware Funds by Macquarie registrants listed on Appendix A hereto (each a “Registrant” and collectively, the “Registrants”), the following are the Registrants’ responses to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) communicated telephonically on August 31, 2022 with respect to each Registrant’s most recent shareholder reports (each, a “Shareholder Report” and collectively, the “Shareholder Reports”). Each Staff comment is summarized below, followed by the response of the Registrant(s) to the comment.
1.
Comment: Please confirm EDGAR has been updated to reflect Fund name changes and share classes that are no longer active.
Response: The Registrants are in the process of updating EDGAR to reflect Fund name changes and inactive share classes, as applicable, for the Registrants listed on Appendix A.
2.
Comment: The below listed Funds reported high portfolio turnover in their respective financial highlights. Please explain if active and frequent trading is part of the Fund’s principal investment strategy, and if yes, why an applicable risk is not included as a principal risk in the summary prospectus.
•
Delaware Ivy Energy Fund
•
Delaware Ivy Natural Resources Fund
•
Delaware Global Value Equity Fund
•
Delaware Ivy International Value Fund
Response: None of the Funds uses active and frequent trading as a principal investment strategy. The higher one-year portfolio turnover rates were due to changes in investment strategies and portfolio managers in November 2021 for the Delaware Ivy Natural Resources Fund and Delaware Global Value
Mindy Rotter
February 8, 2023
Page 2 of 11
Equity Fund; to a change in portfolio managers in November 2021 for the Delaware Climate Solutions Fund (formerly, the Delaware Ivy Energy Fund); and to a change in portfolio managers and sub-advisers for the Delaware Ivy International Value Fund.
3.
Comment: The audit opinions for the Delaware Healthcare Fund and the Delaware Small Cap Growth Fund are each dated May 31, 2022 which is more than 60 days after the Funds’ March 31 fiscal year ends. The Staff notes that Rule 30e-1(c) under the Investment Company Act of 1940, as amended (“1940 Act”), states that when transmitting reports to shareholders, “[e]ach report shall be transmitted within 60 days after the close of the period for which such report is being made.” (Emphasis added.)
The Staff also notes that reliance on Rule 0-3 under the Securities Exchange Act of 1934 which indicates that filings with due dates that fall on a Saturday, Sunday or holiday are still in compliance when filed on the next business day applies to filings, not to “transmitting reports to shareholders” such as annual and semi-annual reports required to be transmitted within 60 days. The Staff maintains that with respect to transmitting reports to shareholders, if the 60th day falls on a Saturday, Sunday or holiday, the report may have to be transmitted earlier than the 60th day to be in compliance with Rule 30e-1(c).
Please explain whether the Registrants will be updating their controls to ensure that future N-CSR or N-CSRS filings are transmitted on a timely basis as outlined above.
Response: The Registrants will review their controls and will make changes to ensure that shareholder reports are transmitted within 60 days of their fiscal year ends, which may require transmission earlier than the 60th day to be in compliance with Rule 30e-1(c) if the 60th days falls on a weekend or holiday.
4.
Comment: The report of independent registered public accounting firm contained in the September 2021 annual shareholder report for the Delaware Ivy High Income Opportunities Fund notes “our procedures included confirmation of securities owned as of June 30, 2021.” However, the Fund’s fiscal year end is September 30. Please correct the opinion and file an amended N-CSR as soon as possible.
Response: The requested change will be made and an amended N-CSR will be filed reflecting the correction of the error. The Registrant anticipates filing an amended N-CSR by February 28, 2023.
5.
Comment: The report of independent registered public accounting firm contained in the annual shareholder report for the Ivy Funds’ fiscal year end March 31, 2022 misstated the money market fund name. Please correct the report and refile.
Response: The requested change will be made. The Registrant anticipates filing an amended N-CSR to reflect the revision by February 28, 2023.
6.
Comment: For the Funds listed as 1-27, 75-81 and 86-88 on Appendix A, Item 2 on their Forms N-CSR notes that the applicable Registrant has adopted a code of ethics that applies to its principal executive officer, principal financial offer, principal accounting officer or controller, or persons performing similar functions, a copy of which has been posted on the Funds’ website. Supplementally, please explain where the business code of ethics is located, including a web link.
Response: The business code of ethics can be accessed by clicking on Additional Information/Business ethics at the bottom of the mutual funds’ home page on the delawarefunds.com website. The direct link is: https://www.delawarefunds.com/about/business-ethics.
Mindy Rotter
February 8, 2023
Page 3 of 11
7.
Comment: During the previous Sarbanes-Oxley review of the Ivy Funds, the staff requested confirmation that the Delaware Ivy Asset Strategy Fund apply Financial Accounting Standards Board Accounting Standards Codification 850 (“FASB 850”), and that the Fund file Form 40-33, with respect to a stockholders’ derivative action. The correspondence confirmed that the Fund complied with FASB 850, but acknowledged that it had not filed the Form 40-33 and undertook to do so as soon as possible. Please provide the link to the firm filing in EDGAR and the specific date the form was filed.
Response: The Registrant did not file Form 40-33, which request was made prior to the Fund becoming part of the Delaware Funds by Macquarie complex. The Registrant filed the Form on February 1, 2023.
8.
Comment: Please explain how the Macquarie Emerging Markets Portfolio II meets diversification requirements under the 1940 Act considering that individual investments representing more than 5% of its total assets are greater than 25% of its total assets.
Response: Fund management has reviewed the schedule of investments in the Fund’s October 2021 annual report. At the time of the report, certain individual investments exceeded 5% of the Fund’s total assets due to their appreciation in value after purchase by the Fund. Accordingly, the Registrant believes that the Fund’s portfolio was diversified at the end of the reporting period for the October 2021 annual report.
9.
Comment: The annual report for the Funds listed below identify them as non-diversified within the meaning of the 1940 Act; however, each Fund appears to be operating as a diversified fund. If a Fund has been operating as a diversified fund for more than three years, please confirm that such Fund will solicit shareholder approval prior to resuming operations as a non-diversified Fund.
•
Delaware Ivy High Income Opportunities Fund
•
Delaware Ivy VIP Natural Resources
•
Delaware Ivy VIP Science and Technology
•
Delaware Ivy Emerging Markets Local Currency Debt Fund
•
Delaware Ivy LaSalle Global Real Estate Fund
•
Delaware Ivy Natural Resources Fund
Response: The Registrants’ investment risk group has confirmed that the Delaware Ivy VIP Science and Technology, Delaware Ivy Emerging Markets Local Currency Debt Fund and Delaware Ivy LaSalle Global Real Estate Fund have operated as non-diversified for all, or parts, of the past three years. The Registrant confirms that if a previously non-diversified Fund has been operating continuously as a diversified Fund for three or more years, shareholder approval will be sought before converting back to a non-diversified Fund.
10.
Comment: The Statement of Assets and Liabilities in the 2021 annual report for the Delaware Ivy Accumulative Fund disclosed securities lending activities. However, the Fund’s Form N-CEN filed on September 3, 2021 did not disclose that the Fund lent securities. Please explain this discrepancy.
Response: Management Investment Record: 2 for Delaware Ivy Accumulative Fund shows that it responded affirmatively to Item C.6.b, indicating that the Fund had lent portfolio securities during the reporting period. Therefore, the Registrant does not believe there is a discrepancy between the Fund’s annual report and Form N-CEN disclosures.
Mindy Rotter
February 8, 2023
Page 4 of 11
11.
Comment: The Notes to the Financial Statements in the 2021 annual report for the Delaware Ivy Wilshire Global Allocation Fund disclosed reimbursement for costs of defense of a derivatives action. The staff notes that on the Form N-CEN for the period ended June 30, 2021, which was filed on September 3, 2021, the Registrant responded “no” to Item B.11.b regarding legal proceedings. Please explain this discrepancy.
Response: Item B.11.b asks if any proceeding previously reported has been terminated. Because the derivative action described in the Fund’s Notes to Financial Statements was not material it had not been previously reported on Form N-CEN, Item B.11.a. Accordingly, the Registrant responded in the negative to Item B.11.b. The reason that the reimbursement payment was reported in the Notes was because the payment flowed through to the Fund’s financial statements and an explanation was required by GAAP, not because the litigation was material.
12.
Comment: In their annual report, the Funds listed below noted that their Board of Trustees had approved the Funds’ liquidation. Please confirm whether the liquidations have occurred and provide specifics relating to said liquidations. If not, please provide the estimated date of liquidation. If there are other funds to be liquidated, please disclose same.
•
Delaware Ivy VIP Global Bond
•
Delaware Ivy VIP Government Money Market
•
Delaware Ivy Cash Management Fund
•
Delaware Ivy ProShares Interest Rate Hedged High Yield Index Fund
•
Delaware Ivy ProShares MSCI ACWI Index Fund
•
Delaware Ivy ProShares Russell 2000 Dividend Growers Index Fund
•
Delaware Ivy ProShares S&P 500 Bond Index Fund
Response: The Registrants confirm that the Funds have liquidated following Board approval, notice to shareholders, the orderly liquidation of the Funds’ portfolios and the pro rata distribution of the proceeds to shareholders. In addition, the Macquarie Emerging Markets Portfolio II was liquidated effective June 30, 2022 following the same process as with the above listed Funds. Finally, the Board has approved the liquidation of the Macquarie Emerging Markets Portfolio and the Macquarie Labor Select International Equity Portfolio. These Portfolios will also follow the same liquidation process as noted for the above listed Funds. The Macquarie Labor Select International Equity Portfolio was liquidated on December 8, 2022 and the Registrant anticipates completing the liquidation of the Macquarie Emerging Markets Portfolio by the end of the first quarter of 2023.
13.
Comment: The staff noted that the Form N-CEN filings for the Registrants listed below indicated that there was a change in accountants. The staff, however, did not see an “agreement letter” from the Funds’ predecessor auditor attached as an exhibit to Item 13(a)(4) in Form N-CSR. Please refer to Dear CFO letter 1998-04 for the disclosure requirements regarding a change in auditor and amend the filings accordingly.
•
Delaware Ivy High Income Opportunities Fund (FYE 9/30/2021; report filed 12/2/2021)
•
Ivy Funds (FYE 6/30/21; report filed 9/3/2021)
•
Ivy Variable Insurance Portfolios (FYE 12/31/2021; report filed 3/10/2022)
•
InvestEd Portfolios (FYE 12/31/2021; report filed 3/10/2022)
Mindy Rotter
February 8, 2023
Page 5 of 11
Response: The foregoing Registrants will amend their applicable Form N-CSR filings to include the predecessor’s auditor agreement letter as an exhibit. The Registrants anticipate filing amended N-CSRs by February 28, 2023.
14.
Comment: A review of the Funds’ applicable annual reports on Form N-CSR showed that they had not included the required disclosure concerning the operation of their liquidity risk management program. This comment applies to all of the Funds listed on Appendix A except for the following: Delaware Ivy Accumulative Fund, Delaware Ivy Wilshire Global Allocation Fund, Macquarie Emerging Markets Portfolio, Macquarie Emerging Markets Portfolio II Fund, Macquarie Labor Select International Equity Portfolio Fund, Delaware Global Listed Real Assets Fund, Macquarie High Yield Bond Portfolio Fund, Macquarie Core Plus Bond Portfolio Fund, and Macquarie Large Cap Value Portfolio Fund. Please explain why the disclosure was not included.
Response: The liquidity risk management program statement is included under the “Other information” section in the Ivy Variable Insurance Portfolios’ semi-annual report for the period ended June 30, 2021; in the Healthcare, Smid Cap Core and Small Cap Growth Funds’ semi-annual reports for the period ended September 30, 2021; in the Delaware Limited-Term Diversified Income Fund’s semi-annual report dated June 30, 2021; and in the Delaware Tax-Free New Jersey and Delaware Tax-Free Oregon Funds’ semi-annual report dated June 30, 2021. In addition, for 2022, the liquidity risk management disclosure for the Ivy Funds was moved from the annual/semi-annual reports for the period ended March 31 to the annual/semi-annu
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2005 Market Street, Suite 2600
Philadelphia, PA 19103-7098
T: (215) 564-8099
F: (215) 564-8120
February 8, 2023
Via EDGAR Transmission
Mindy Rotter, Esq., CPA
Division of Investment Management
Disclosure Review and Accounting Office
U.S. Securities and Exchange Commission
New York Regional Office
100 Pearl Street, Suite 20-100
New York, NY 10004-2616
Re:
Sarbanes-Oxley Review of Shareholder Reports for Various Delaware Funds by Macquarie® Registrants
Dear Ms. Rotter:
On behalf of each of the Delaware Funds by Macquarie registrants listed on Appendix A hereto (each a “Registrant” and collectively, the
“Registrants”), the following are the Registrants’ responses to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) communicated telephonically on August 31, 2022 with respect to each Registrant’s most
recent shareholder reports (each, a “Shareholder Report” and collectively, the “Shareholder Reports”). Each Staff comment is summarized below, followed by the response of the Registrant(s) to the comment.
1.
Comment: Please confirm EDGAR has been updated to reflect Fund name changes and share classes that are no longer active.
Response: The Registrants are in the process of updating EDGAR to reflect Fund name changes and inactive share classes, as applicable, for the Registrants listed on
Appendix A.
2.
Comment: The below listed Funds reported high portfolio turnover in their respective financial highlights. Please explain if active and frequent trading is part of the
Fund’s principal investment strategy, and if yes, why an applicable risk is not included as a principal risk in the summary prospectus.
•
Delaware Ivy Energy Fund
•
Delaware Ivy Natural Resources Fund
•
Delaware Global Value Equity Fund
•
Delaware Ivy International Value Fund
Response: None of the Funds uses active and frequent trading as a principal investment strategy. The higher one-year portfolio turnover rates were due to changes in
investment strategies and portfolio managers in November 2021 for the Delaware Ivy Natural Resources Fund and Delaware Global Value
Mindy Rotter
February 8, 2023
Page 2 of 11
Equity Fund; to a change in portfolio managers in November 2021 for the Delaware Climate Solutions Fund (formerly, the Delaware Ivy Energy Fund); and to a change in portfolio
managers and sub-advisers for the Delaware Ivy International Value Fund.
3.
Comment: The audit opinions for the Delaware Healthcare Fund and the Delaware Small Cap Growth Fund are each dated May 31, 2022 which is more than 60 days after the
Funds’ March 31 fiscal year ends. The Staff notes that Rule 30e-1(c) under the Investment Company Act of 1940, as amended (“1940 Act”), states that when transmitting reports to shareholders, “[e]ach report shall be transmitted within 60 days after the close of the period for which such report is being made.” (Emphasis added.)
The Staff also notes that reliance on Rule 0-3 under the Securities Exchange Act of 1934 which indicates that filings with due dates that fall on a Saturday, Sunday or holiday
are still in compliance when filed on the next business day applies to filings, not to “transmitting reports to shareholders” such as annual and semi-annual reports required to be transmitted within 60 days. The Staff maintains that with
respect to transmitting reports to shareholders, if the 60th day falls on a Saturday, Sunday or holiday, the report may have to be transmitted earlier than the 60th day to be in compliance with Rule 30e-1(c).
Please explain whether the Registrants will be updating their controls to ensure that future N-CSR or N-CSRS filings are transmitted on a timely basis as outlined above.
Response: The Registrants will review their controls and will make changes to ensure that shareholder reports are transmitted within 60 days of their fiscal year ends,
which may require transmission earlier than the 60th day to be in compliance with Rule 30e-1(c) if the 60th days falls on a weekend or holiday.
4.
Comment: The report of independent registered public accounting firm contained in the September 2021 annual shareholder report for the Delaware Ivy High Income
Opportunities Fund notes “our procedures included confirmation of securities owned as of June 30, 2021.” However, the Fund’s fiscal year end is September 30. Please correct the opinion and file an amended N-CSR as soon as possible.
Response: The requested change will be made and an amended N-CSR will be filed reflecting the correction of the error. The Registrant anticipates filing an amended
N-CSR by February 28, 2023.
5.
Comment: The report of independent registered public accounting firm contained in the annual shareholder report for the Ivy Funds’ fiscal year end March 31, 2022
misstated the money market fund name. Please correct the report and refile.
Response: The requested change will be made. The Registrant anticipates filing an amended N-CSR to reflect the revision by February 28, 2023.
6.
Comment: For the Funds listed as 1-27, 75-81 and 86-88 on Appendix A, Item 2 on their Forms N-CSR notes that the applicable Registrant has adopted a code of ethics that
applies to its principal executive officer, principal financial offer, principal accounting officer or controller, or persons performing similar functions, a copy of which has been posted on the Funds’ website. Supplementally, please explain
where the business code of ethics is located, including a web link.
Response: The business code of ethics can be accessed by clicking on Additional Information/Business ethics at the bottom of the
mutual funds’ home page on the delawarefunds.com website. The direct link is: https://www.delawarefunds.com/about/business-ethics.
Mindy Rotter
February 8, 2023
Page 3 of 11
7.
Comment: During the previous Sarbanes-Oxley review of the Ivy Funds, the staff requested confirmation that the Delaware Ivy Asset Strategy Fund apply Financial
Accounting Standards Board Accounting Standards Codification 850 (“FASB 850”), and that the Fund file Form 40-33, with respect to a stockholders’ derivative action. The correspondence confirmed that the Fund complied with FASB 850, but
acknowledged that it had not filed the Form 40-33 and undertook to do so as soon as possible. Please provide the link to the firm filing in EDGAR and the specific date the form was filed.
Response: The Registrant did not file Form 40-33, which request was made prior to the Fund becoming part of the Delaware Funds by Macquarie complex. The Registrant
filed the Form on February 1, 2023.
8.
Comment: Please explain how the Macquarie Emerging Markets Portfolio II meets diversification requirements under the 1940 Act considering that individual investments
representing more than 5% of its total assets are greater than 25% of its total assets.
Response: Fund management has reviewed the schedule of investments in the Fund’s October 2021 annual report. At the time of the report, certain individual investments
exceeded 5% of the Fund’s total assets due to their appreciation in value after purchase by the Fund. Accordingly, the Registrant believes that the Fund’s portfolio was diversified at the end of the reporting period for the October 2021
annual report.
9.
Comment: The annual report for the Funds listed below identify them as non-diversified within the meaning of the 1940 Act; however, each Fund appears to be operating as
a diversified fund. If a Fund has been operating as a diversified fund for more than three years, please confirm that such Fund will solicit shareholder approval prior to resuming operations as a non-diversified Fund.
•
Delaware Ivy High Income Opportunities Fund
•
Delaware Ivy VIP Natural Resources
•
Delaware Ivy VIP Science and Technology
•
Delaware Ivy Emerging Markets Local Currency Debt Fund
•
Delaware Ivy LaSalle Global Real Estate Fund
•
Delaware Ivy Natural Resources Fund
Response: The Registrants’ investment risk group has confirmed that the Delaware Ivy VIP Science and Technology, Delaware Ivy Emerging Markets Local Currency Debt Fund
and Delaware Ivy LaSalle Global Real Estate Fund have operated as non-diversified for all, or parts, of the past three years. The Registrant confirms that if a previously non-diversified Fund has been operating continuously as a diversified
Fund for three or more years, shareholder approval will be sought before converting back to a non-diversified Fund.
10.
Comment: The Statement of Assets and Liabilities in the 2021 annual report for the Delaware Ivy Accumulative Fund disclosed securities lending activities. However, the
Fund’s Form N-CEN filed on September 3, 2021 did not disclose that the Fund lent securities. Please explain this discrepancy.
Response: Management Investment Record: 2 for Delaware Ivy Accumulative Fund shows that it responded affirmatively to Item C.6.b, indicating that the Fund had lent
portfolio securities during the reporting period. Therefore, the Registrant does not believe there is a discrepancy between the Fund’s annual report and Form N-CEN disclosures.
Mindy Rotter
February 8, 2023
Page 4 of 11
11.
Comment: The Notes to the Financial Statements in the 2021 annual report for the Delaware Ivy Wilshire Global Allocation Fund disclosed reimbursement for costs of
defense of a derivatives action. The staff notes that on the Form N-CEN for the period ended June 30, 2021, which was filed on September 3, 2021, the Registrant responded “no” to Item B.11.b regarding legal proceedings. Please explain this
discrepancy.
Response: Item B.11.b asks if any proceeding previously reported has been terminated. Because the derivative action described in the Fund’s Notes to Financial
Statements was not material it had not been previously reported on Form N-CEN, Item B.11.a. Accordingly, the Registrant responded in the negative to Item B.11.b. The reason that the reimbursement payment was reported in the Notes was because
the payment flowed through to the Fund’s financial statements and an explanation was required by GAAP, not because the litigation was material.
12.
Comment: In their annual report, the Funds listed below noted that their Board of Trustees had approved the Funds’ liquidation. Please confirm whether the liquidations
have occurred and provide specifics relating to said liquidations. If not, please provide the estimated date of liquidation. If there are other funds to be liquidated, please disclose same.
•
Delaware Ivy VIP Global Bond
•
Delaware Ivy VIP Government Money Market
•
Delaware Ivy Cash Management Fund
•
Delaware Ivy ProShares Interest Rate Hedged High Yield Index Fund
•
Delaware Ivy ProShares MSCI ACWI Index Fund
•
Delaware Ivy ProShares Russell 2000 Dividend Growers Index Fund
•
Delaware Ivy ProShares S&P 500 Bond Index Fund
Response: The Registrants confirm that the Funds have liquidated following Board approval, notice to shareholders, the orderly liquidation of the Funds’ portfolios and
the pro rata distribution of the proceeds to shareholders. In addition, the Macquarie Emerging Markets Portfolio II was liquidated effective June 30, 2022 following the same process as with the above listed Funds. Finally, the Board has
approved the liquidation of the Macquarie Emerging Markets Portfolio and the Macquarie Labor Select International Equity Portfolio. These Portfolios will also follow the same liquidation process as noted for the above listed Funds. The
Macquarie Labor Select International Equity Portfolio was liquidated on December 8, 2022 and the Registrant anticipates completing the liquidation of the Macquarie Emerging Markets Portfolio by the end of the first quarter of 2023.
13.
Comment: The staff noted that the Form N-CEN filings for the Registrants listed below indicated that there was a change in accountants. The staff, however, did not see
an “agreement letter” from the Funds’ predecessor auditor attached as an exhibit to Item 13(a)(4) in Form N-CSR. Please refer to Dear CFO letter 1998-04 for the disclosure requirements regarding a change in auditor and amend the filings
accordingly.
•
Delaware Ivy High Income Opportunities Fund (FYE 9/30/2021; report filed 12/2/2021)
•
Ivy Funds (FYE 6/30/21; report filed 9/3/2021)
•
Ivy Variable Insurance Portfolios (FYE 12/31/2021; report filed 3/10/2022)
•
InvestEd Portfolios (FYE 12/31/2021; report filed 3/10/2022)
Mindy Rotter
February 8, 2023
Page 5 of 11
Response: The foregoing Registrants will amend their applicable Form N-CSR filings to include the predecessor’s auditor agreement letter as an exhibit. The Registrants anticipate filing amended N-CSRs by February 28, 2023.
14.
Comment: A review of the Funds’ applicable annual reports on Form N-CSR showed that they had not included the required disclosure concerning the operation of their
liquidity risk management program. This comment applies to all of the Funds listed on Appendix A except for the following: Delaware Ivy Accumulative Fund, Delaware Ivy Wilshire Global Allocation Fund, Macquarie Emerging Markets Portfolio,
Macquarie Emerging Markets Portfolio II Fund, Macquarie Labor Select International Equity Portfolio Fund, Delaware Global Listed Real Assets Fund, Macquarie High Yield Bond Portfolio Fund, Macquarie Core Plus Bond Portfolio Fund, and
Macquarie Large Cap Value Portfolio Fund. Please explain why the disclosure was not included.
Response: The liquidity risk management program statement is included under the “Other information” section in the Ivy Variable Insurance Portfolios’ semi-annual
report for the period ended June 30, 2021; in the Healthcare, Smid Cap Core and Small Cap Growth Funds’ semi-annual reports for the period ended September 30, 2021; in the Delaware Limited-Term Diversified Income Fund’s semi-annual report
dated June 30, 2021; and in the Delaware Tax-Free New Jersey and Delaware Tax-Free Oregon Funds’ semi-annual report dated June 30, 2021. In addition, for 2022, the liquidity risk management disclosure for the Ivy Funds was moved from the
annual/semi-annual reports for the period ended March 31 to the annual/semi-annu