Correspondence 0001193125-24-117467 from PCM FUND, INC. (PCM) (CIK 0000908187) (PCM)
PCM FUND, INC. (PCM) (CIK 0000908187)
Date: April 26, 2024 · CIK: 0000908187 · Accession: 0001193125-24-117467
AI Filing Summary & Sentiment
File numbers found in text: 811-08216, 811-10555, 811-21238, 811-21311, 811-21374, 811-21601, 811-21734, 811-22673, 811-23211, 811-23390, 811-23505, 811-23648, 811-23749
Letter
VIA EDGAR CORRESPONDENCE Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Attn: Ken Ellington Re: Sarbanes-Oxley Review of PIMCO Closed-End Funds
Dear Mr. Ellington:
Thank you for your oral comments provided on February 1, 2024, regarding the staff of the Securities and Exchange Commission’s (the “SEC”) review, pursuant to the Sarbanes-Oxley Act of 2002, of the financial statements contained in the reports to shareholders, as well as related disclosures in the prospectuses and other filings of the PIMCO closed-end funds listed on Appendix A, attached hereto (each a “Fund,” and collectively, the “Funds”), for the fiscal year ended June 30, 2023 (the “2023 Annual Report”). Your comments are summarized below to the best of our understanding, followed by the Funds’ responses. Unless otherwise noted, the responses relate to all Funds.
* * *
1. Comment: PCM Fund, Inc. (“PCM”) appears to hold a number of securities that are identified as in default on the schedule of investments. The majority of these securities are not marked as non-income producing. Please explain.
Response: Many of the positions identified as “defaulted” in the Fund’s Schedule of Investments produced income during the reporting period.
2. Comment: It appears that PIMCO Corporate & Income Opportunity Fund, PIMCO Corporate & Income Strategy Fund, PIMCO Flexible Emerging Markets Income Fund, PIMCO High Income Fund, PIMCO Income Strategy Fund and PIMCO Income Strategy Fund II each have significant investments in bank loans. If the Funds received consent fees, upfront origination fees, and/or amendment fee income from such loans (which is different from interest income), please ensure that such income amounts are disclosed appropriately in the notes to the financial statements, along with the policy to recognize such income in accordance with applicable U.S. GAAP.
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April 26, 2024
Response: The Fund will add the requested income amounts, as appropriate, in future filings on Form N-CSR when such income amounts are material.
3. Comment: The disclosure above the “Effects of Leverage” table in the 2023 Annual Report for PCM, PIMCO Global StocksPLUS® & Income Fund, PIMCO Strategic Income Fund, Inc., PIMCO Access Income Fund, PIMCO Dynamic Income Fund and PIMCO Dynamic Income Opportunities Fund states that it is based on market conditions as of June 30, 2019. Please confirm if this disclosure is accurate and ensure that this information is updated to a more recent date going forward.
Response: The “Effects of Leverage” table in the 2023 Annual Report related to the fiscal year ended June 30, 2023 and the reference to “June 30, 2019” was a typographical error (i.e., the reference should have been to “June 30, 2023”). The correct “market conditions as of” date will be referenced in future “Effects of Leverage” tables.
* * *
We hope the foregoing responses adequately address the SEC staff’s comments. Should you have any further questions or comments, please do not hesitate to contact me at (617) 951-7114.
Sincerely,
/s/ Adam M. Schlichtmann
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CORRESP 1 filename1.htm CORRESP ROPES & GRAY LLP PRUDENTIAL TOWER 800 BOYLSTON STREET BOSTON, MA 02199-3600 WWW.ROPESGRAY.COM April 26, 2024 Adam M. Schlichtmann T +1 617 951 7114 F +1 617 235 7346 adam.schlichtmann@ropesgray.com VIA EDGAR CORRESPONDENCE Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Attn: Ken Ellington Re: Sarbanes-Oxley Review of PIMCO Closed-End Funds Dear Mr. Ellington: Thank you for your oral comments provided on February 1, 2024, regarding the staff of the Securities and Exchange Commission’s (the “SEC”) review, pursuant to the Sarbanes-Oxley Act of 2002, of the financial statements contained in the reports to shareholders, as well as related disclosures in the prospectuses and other filings of the PIMCO closed-end funds listed on Appendix A, attached hereto (each a “Fund,” and collectively, the “Funds”), for the fiscal year ended June 30, 2023 (the “2023 Annual Report”). Your comments are summarized below to the best of our understanding, followed by the Funds’ responses. Unless otherwise noted, the responses relate to all Funds. * * * 1. Comment: PCM Fund, Inc. (“PCM”) appears to hold a number of securities that are identified as in default on the schedule of investments. The majority of these securities are not marked as non-income producing. Please explain. Response: Many of the positions identified as “defaulted” in the Fund’s Schedule of Investments produced income during the reporting period. 2. Comment: It appears that PIMCO Corporate & Income Opportunity Fund, PIMCO Corporate & Income Strategy Fund, PIMCO Flexible Emerging Markets Income Fund, PIMCO High Income Fund, PIMCO Income Strategy Fund and PIMCO Income Strategy Fund II each have significant investments in bank loans. If the Funds received consent fees, upfront origination fees, and/or amendment fee income from such loans (which is different from interest income), please ensure that such income amounts are disclosed appropriately in the notes to the financial statements, along with the policy to recognize such income in accordance with applicable U.S. GAAP. - 2 - April 26, 2024 Response: The Fund will add the requested income amounts, as appropriate, in future filings on Form N-CSR when such income amounts are material. 3. Comment: The disclosure above the “Effects of Leverage” table in the 2023 Annual Report for PCM, PIMCO Global StocksPLUS® & Income Fund, PIMCO Strategic Income Fund, Inc., PIMCO Access Income Fund, PIMCO Dynamic Income Fund and PIMCO Dynamic Income Opportunities Fund states that it is based on market conditions as of June 30, 2019. Please confirm if this disclosure is accurate and ensure that this information is updated to a more recent date going forward. Response: The “Effects of Leverage” table in the 2023 Annual Report related to the fiscal year ended June 30, 2023 and the reference to “June 30, 2019” was a typographical error (i.e., the reference should have been to “June 30, 2023”). The correct “market conditions as of” date will be referenced in future “Effects of Leverage” tables. * * * We hope the foregoing responses adequately address the SEC staff’s comments. Should you have any further questions or comments, please do not hesitate to contact me at (617) 951-7114. Sincerely, /s/ Adam M. Schlichtmann Adam M. Schlichtmann cc: Ryan Leshaw, Pacific Investment Management Company LLC Timothy Bekkers, Pacific Investment Management Company LLC Jaime Dinan, Pacific Investment Management Company LLC Appendix A File No. Registrant/Series Name 811-21238 PCM Fund, Inc. 811-21734 PIMCO Global StocksPLUS® & Income Fund 811-08216 PIMCO Strategic Income Fund, Inc. 811-23749 PIMCO Access Income Fund 811-22673 PIMCO Dynamic Income Fund 811-23505 PIMCO Dynamic Income Opportunities Fund 811-23390 PIMCO Dynamic Income Strategy Fund 811-21238 PIMCO Corporate & Income Opportunity Fund 811-10555 PIMCO Corporate & Income Strategy Fund 811-21311 PIMCO High Income Fund 811-21374 PIMCO Income Strategy Fund 811-21601 PIMCO Income Strategy Fund II 811-23211 PIMCO Flexible Credit Income Fund 811-23648 PIMCO Flexible Emerging Markets Income Fund