SEC Company Response from NUVEEN CALIFORNIA AMT-FREE QUALITY MUNICIPAL INCOME FUND (NKX) (CIK 0001195738) (NKX) — Mar 11, 2020
NUVEEN CALIFORNIA AMT-FREE QUALITY MUNICIPAL INCOME FUND (NKX) (CIK 0001195738)
Date: March 11, 2020 · CIK: 0001195738 · Accession: 0001193125-20-070436
AI Filing Summary & Sentiment
File numbers found in text: 333-225399, 811-21212
Letter
Division of Investment Management 100 F Street NE Washington, DC 20549 Re: Nuveen California AMT-Free Quality Municipal Income Fund (the “Fund”) File Nos. 333-225399 and 811-21212
Dear Ms. Bentzinger:
The purpose of this letter is to respond to comments relating to the Fund’s initial registration statement on Form N-2, which was filed on June 4, 2018 for the purpose of registering additional common shares of the Fund. The following summarizes your comments and the Fund’s responses. Unless otherwise noted, capitalized terms have the same meaning as contained in the Fund’s Prospectus or Form N-2.
1. Comment: Please confirm in your response letter that FINRA has reviewed the proposed underwriting terms and arrangements for the transactions described in the registration statement, including the amount of compensation to be allowed or paid to the underwriters and any other arrangements among the Fund, the underwriters, and other broker dealers participating in the distribution, and that FINRA has issued a statement expressing no objections to the compensation and other arrangements.
Response: The Fund so confirms.
2. Comment: Please consider providing principal risk disclosure addressing how the transition from LIBOR could affect the Fund’s investments.
Response: The Fund does not consider the transition from LIBOR to be a principal risk for the Fund at this time and therefore respectfully declines to add the requested disclosure. The Fund continues to monitor its risk disclosure in order to determine whether to add disclosure.
3. Comment: Please confirm supplementally that the Fund will file with the Commission final versions of agreements required to be filed pursuant to Item 25.2 of Form N-2.
Response: The Fund so confirms.
Morgan, Lewis & Bockius LLP
1111 Pennsylvania Avenue, NW
Washington, DC 20004
United States
+1.202.739.3000
+1.202.739.3001
Elisabeth Bentzinger
March 11, 2020
Page 2
*************
If you have any additional questions or comments, please do not hesitate to contact me at 202.373.6149.
Sincerely yours,
/s/ Kathleen M. Macpeak
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CORRESP 1 filename1.htm NUVEEN CALIFORNIA AMT-FREE QUALITY MUNICIPAL INCOME FUND Kathleen M. Macpeak +1.202.373.6149 kathleen.macpeak@morganlewis.com March 11, 2020 Elisabeth Bentzinger U.S. Securities and Exchange Commission Division of Investment Management 100 F Street NE Washington, DC 20549 Re: Nuveen California AMT-Free Quality Municipal Income Fund (the “Fund”) File Nos. 333-225399 and 811-21212 Dear Ms. Bentzinger: The purpose of this letter is to respond to comments relating to the Fund’s initial registration statement on Form N-2, which was filed on June 4, 2018 for the purpose of registering additional common shares of the Fund. The following summarizes your comments and the Fund’s responses. Unless otherwise noted, capitalized terms have the same meaning as contained in the Fund’s Prospectus or Form N-2. 1. Comment: Please confirm in your response letter that FINRA has reviewed the proposed underwriting terms and arrangements for the transactions described in the registration statement, including the amount of compensation to be allowed or paid to the underwriters and any other arrangements among the Fund, the underwriters, and other broker dealers participating in the distribution, and that FINRA has issued a statement expressing no objections to the compensation and other arrangements. Response: The Fund so confirms. 2. Comment: Please consider providing principal risk disclosure addressing how the transition from LIBOR could affect the Fund’s investments. Response: The Fund does not consider the transition from LIBOR to be a principal risk for the Fund at this time and therefore respectfully declines to add the requested disclosure. The Fund continues to monitor its risk disclosure in order to determine whether to add disclosure. 3. Comment: Please confirm supplementally that the Fund will file with the Commission final versions of agreements required to be filed pursuant to Item 25.2 of Form N-2. Response: The Fund so confirms. Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 United States +1.202.739.3000 +1.202.739.3001 Elisabeth Bentzinger March 11, 2020 Page 2 ************* If you have any additional questions or comments, please do not hesitate to contact me at 202.373.6149. Sincerely yours, /s/ Kathleen M. Macpeak Kathleen M. Macpeak cc: Gifford Zimmerman Mark Winget