Correspondence 0001104129-25-000004 from Core Bond Portfolio (CIK 0001104129)
Core Bond Portfolio (CIK 0001104129)
Date: July 15, 2025 · CIK: 0001104129 · Accession: 0001104129-25-000004
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 811-01241, 811-01545, 811-02589, 811-04015, 811-07409, 811-08134, 811-08340, 811-09833, 811-10067, 811-21670, 811-22336, 811-22777
Letter
VIA EDGAR Division of Investment Management New York Regional Office 100 Pearl Street, Suite 20-100 New York, NY 10004-2616 Re: Core Bond Portfolio (File No. 811-09833); Eaton Vance Enhanced Equity Income Fund II (File No. 811-21670); Eaton Vance Growth Trust (File No. 811-01241); Eaton Vance Municipal Income 2028 Term Trust (File No. 811-22777); Eaton Vance Municipals Trust II (File No. 811-08134); Eaton Vance Mutual Funds Trust (File No. 811-04015); Eaton Vance Series Trust (File No. 811-02589); Eaton Vance Special Investment Trust (File No. 811-01545); Eaton Vance Variable Trust (File No. 811-10067); Greater India Portfolio (File No. 811-08340); Stock Portfolio (File No. 811-22336); Tax-Managed Growth Portfolio (File No. 811-07409) (each, a "Registrant")
Dear Mr. Ellington,
This letter is in response to the comments you provided telephonically to Lisa Henry of Ropes & Gray LLP on June 25, 2025 with respect to the Forms N-CSR filed by the series of the Registrants listed on Appendix A attached hereto (each, a "Fund" and collectively, the "Funds") for the fiscal periods ended November 30, 2024, December 31, 2024, January 31, 2025, and February 28, 2025. The comments and Registrants' responses thereto are set forth below. Changes referenced in responses below will be incorporated into Forms N-CSR and other applicable regulatory filings going forward, as noted below.
Comments and Responses
1. Comment : In the schedule of investments for Eaton Vance VT Floating Rate Income Fund, please disclose a dividend rate (if known) for all preferred stocks held by the Fund as part of the title of issue. If the preferred stocks are not income producing, please identify them as such. See Article 12-12 of Regulation S-X.
Response : The preferred stocks held by Eaton Vance VT Floating-Rate Income Fund do not have a dividend rate. The footnote identifying these preferred stocks as non-income producing was inadvertently omitted from the schedule of investments for this Fund. The Registrant will add the requested disclosure in future filings.
2. Comment : For all feeder funds, please include information related to any fee waivers at the master fund level on the face of the statement of operations (as a reduction of the expenses of the master fund) or in a footnote to the statement of operations.
Response : In future filings, each Registrant will present separately on the statement of operations of a feeder fund the fee waivers that have been allocated from the master fund, if any.
* * *
If you have any questions or comments concerning the foregoing, please contact the undersigned at 617-951-7780.
Very truly yours,
/s/ Lisa Henry
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CORRESP 1 filename1.htm July 15, 2025 VIA EDGAR Mr. Kenneth Ellington U.S. Securities and Exchange Commission Division of Investment Management Disclosure Review and Accounting Office New York Regional Office 100 Pearl Street, Suite 20-100 New York, NY 10004-2616 Re: Core Bond Portfolio (File No. 811-09833); Eaton Vance Enhanced Equity Income Fund II (File No. 811-21670); Eaton Vance Growth Trust (File No. 811-01241); Eaton Vance Municipal Income 2028 Term Trust (File No. 811-22777); Eaton Vance Municipals Trust II (File No. 811-08134); Eaton Vance Mutual Funds Trust (File No. 811-04015); Eaton Vance Series Trust (File No. 811-02589); Eaton Vance Special Investment Trust (File No. 811-01545); Eaton Vance Variable Trust (File No. 811-10067); Greater India Portfolio (File No. 811-08340); Stock Portfolio (File No. 811-22336); Tax-Managed Growth Portfolio (File No. 811-07409) (each, a "Registrant") Dear Mr. Ellington, This letter is in response to the comments you provided telephonically to Lisa Henry of Ropes & Gray LLP on June 25, 2025 with respect to the Forms N-CSR filed by the series of the Registrants listed on Appendix A attached hereto (each, a "Fund" and collectively, the "Funds") for the fiscal periods ended November 30, 2024, December 31, 2024, January 31, 2025, and February 28, 2025. The comments and Registrants' responses thereto are set forth below. Changes referenced in responses below will be incorporated into Forms N-CSR and other applicable regulatory filings going forward, as noted below. Comments and Responses 1. Comment : In the schedule of investments for Eaton Vance VT Floating Rate Income Fund, please disclose a dividend rate (if known) for all preferred stocks held by the Fund as part of the title of issue. If the preferred stocks are not income producing, please identify them as such. See Article 12-12 of Regulation S-X. Response : The preferred stocks held by Eaton Vance VT Floating-Rate Income Fund do not have a dividend rate. The footnote identifying these preferred stocks as non-income producing was inadvertently omitted from the schedule of investments for this Fund. The Registrant will add the requested disclosure in future filings. 2. Comment : For all feeder funds, please include information related to any fee waivers at the master fund level on the face of the statement of operations (as a reduction of the expenses of the master fund) or in a footnote to the statement of operations. Response : In future filings, each Registrant will present separately on the statement of operations of a feeder fund the fee waivers that have been allocated from the master fund, if any. * * * If you have any questions or comments concerning the foregoing, please contact the undersigned at 617-951-7780. Very truly yours, /s/ Lisa Henry cc: Sarah Clinton, Ropes & Gray LLP Nicholas Di Lorenzo, Morgan Stanley Investment Management Appendix A File # Registrant Name Series ID Series Name FYE Reviewed 811-09833 Core Bond Portfolio S000005237 Core Bond Portfolio 12/31/2024 811-21670 Eaton Vance Enhanced Equity Income Fund II CEF0013140 Eaton Vance Enhanced Equity Income Fund II 12/31/2024 811-01241 Eaton Vance Growth Trust S000031537 Eaton Vance Focused Growth Opportunities Fund 2/28/2025 811-01241 Eaton Vance Growth Trust S000052056 Eaton Vance International Small-Cap Fund 11/30/2024 811-01241 Eaton Vance Growth Trust S000031538 Eaton Vance Focused Value Opportunities Fund 2/28/2025 811-22777 Eaton Vance Municipal Income 2028 Term Trust CEF0013689 Eaton Vance Municipal Income 2028 Term Trust 1/31/2025 811-08134 Eaton Vance Municipals Trust II S000027033 Parametric TABS Intermediate-Term Municipal Bond Fund 1/31/2025 811-08134 Eaton Vance Municipals Trust II S000027034 Parametric TABS 5-To-15 Year Laddered Municipal Bond Fund 1/31/2025 811-08134 Eaton Vance Municipals Trust II S000024906 Parametric TABS Short-Term Municipal Bond Fund 1/31/2025 811-08134 Eaton Vance Municipals Trust II S000049164 Parametric TABS 1-To-10 Year Laddered Municipal Bond Fund 1/31/2025 811-08134 Eaton Vance Municipals Trust II S000004834 Eaton Vance High Yield Municipal Income Fund 1/31/2025 811-04015 Eaton Vance Mutual Funds Trust S000032773 Parametric Commodity Strategy Fund 12/31/2024 811-04015 Eaton Vance Mutual Funds Trust S000012701 Parametric Emerging Markets Fund 1/31/2025 811-04015 Eaton Vance Mutual Funds Trust S000044370 Parametric Dividend Income Fund 2/28/2025 811-04015 Eaton Vance Mutual Funds Trust S000028355 Parametric International Equity Fund 1/31/2025 811-04015 Eaton Vance Mutual Funds Trust S000005293 Eaton Vance Tax-Managed Growth Fund 1.2 12/31/2024 811-04015 Eaton Vance Mutual Funds Trust S000005304 Eaton Vance Tax-Managed Growth Fund 1.1 12/31/2024 811-04015 Eaton Vance Mutual Funds Trust S000005278 Eaton Vance Stock Fund 12/31/2024 811-04015 Eaton Vance Mutual Funds Trust S000056237 Parametric Volatility Risk Premium - Defensive Fund 1/31/2025 811-02589 Eaton Vance Series Trust S000005210 Eaton Vance Tax-Managed Growth Fund 1.0 12/31/2024 811-01545 Eaton Vance Special Investment Trust S000005213 Eaton Vance Balanced Fund 12/31/2024 811-01545 Eaton Vance Special Investment Trust S000005215 Eaton Vance Dividend Builder Fund 12/31/2024 811-01545 Eaton Vance Special Investment Trust S000005217 Eaton Vance Greater India Fund 12/31/2024 811-01545 Eaton Vance Special Investment Trust S000005220 Eaton Vance Growth Fund 12/31/2024 811-01545 Eaton Vance Special Investment Trust S000005221 Eaton Vance Large-Cap Value Fund 12/31/2024 811-01545 Eaton Vance Special Investment Trust S000005222 Eaton Vance Small-Cap Fund 12/31/2024 811-01545 Eaton Vance Special Investment Trust S000012344 Eaton Vance Core Bond Fund 12/31/2024 811-10067 Eaton Vance Variable Trust S000005203 Eaton Vance VT Floating-Rate Income Fund 12/31/2024 811-08340 Greater India Portfolio S000005245 Greater India Portfolio 12/31/2024 811-22336 Stock Portfolio S000027121 Stock Portfolio 12/31/2024 811-07409 Tax-Managed Growth Portfolio S000005248 Tax-Managed Growth Portfolio 12/31/2024