SEC Comment Letter for Eaton Vance Floating-Rate Income Trust (EFT) (CIK 0001288992) (EFT) — Mar 2, 2005
Eaton Vance Floating-Rate Income Trust (EFT) (CIK 0001288992)
Date: March 2, 2005 · CIK: 0001288992 · Accession: 0000000000-05-009897
AI Filing Summary & Sentiment
File numbers found in text: 333-117357, 811-21574
Referenced dates: July 14, 2004
Letter
August 6, 2004 Clair Pagnano, Esq. Kirkpatrick & Lockhart, L.L.P. 75 State Street Boston, Massachusetts 02109
Re: Eaton Vance Floating-Rate Income Trust File Nos. 333-117357 and 811-21574
Dear Ms. Pagnano:
We have reviewed the registration statement on Form N-2 for the Eaton Vance Floating-Rate Income Trust ("Fund"), registering its auction preferred shares, filed with the Commission on July 14, 2004. Your cover letter dated July 14, 2004 requested, and we conducted, a selective review of the registration statement. We have the following comments.
Prospectus
General
1. We note that portions of the filing are incomplete. We may have additional comments on such portions when you complete them in a pre- effective amendment, on disclosures made in response to this letter, on information supplied supplementally, or on exhibits added in any further pre-effective amendments.
2. Please inform the staff of the information the Fund proposes to omit from the final pre-effective amendment pursuant to Rule 430A under the Securities Act.
Prospectus Summary
Please advise us supplementally whether the Fund is currently fully invested. Also advise whether the underwriters of the Fund`s common offering exercised their options to purchase additional shares to cover over-allotments and, if so, whether the underwriters still hold the shares so purchased.
Please advise us supplementally whether the Fund has a strategy concerning the duration of the Fund`s portfolio relative to the auction dates of the preferred shares. Does the Fund have a strategy for dealing with rising interest rates or inverted yield curves?
Financial Highlights
Please advise us supplementally why the Fund will use leverage when it invests substantially in short-term debt.
Statement of Additional Information
Approval of Investment Advisory Agreement This disclosure does not contain a reasonably detailed discussion of the material factors that formed the basis for the board of directors approving the investment advisory contract. Please revise the disclosure accordingly. See Instruction to Item 18.13 of Form N-2. Financial Statements Please include updated financial statements in the disclosure. Please respond to this letter in the form of a pre-effective amendment filed under Rule 472 of the Securities Act. Any questions you may have regarding the filing or this letter may be directed to me at 202.942.0686.
Sincerely,
Vincent J. Di Stefano
Senior Counsel
Show Raw Text
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August 6, 2004
Clair Pagnano, Esq.
Kirkpatrick & Lockhart, L.L.P.
75 State Street
Boston, Massachusetts 02109
Re: Eaton Vance Floating-Rate Income Trust
File Nos. 333-117357 and 811-21574
Dear Ms. Pagnano:
We have reviewed the registration statement on Form N-2 for
the
Eaton Vance Floating-Rate Income Trust ("Fund"), registering its
auction preferred shares, filed with the Commission on July 14,
2004.
Your cover letter dated July 14, 2004 requested, and we conducted,
a
selective review of the registration statement. We have the
following comments.
Prospectus
General
1. We note that portions of the filing are incomplete. We may have
additional comments on such portions when you complete them in a
pre-
effective amendment, on disclosures made in response to this
letter,
on information supplied supplementally, or on exhibits added in
any
further pre-effective amendments.
2. Please inform the staff of the information the Fund proposes to
omit from the final pre-effective amendment pursuant to Rule 430A
under the Securities Act.
Prospectus Summary
Please advise us supplementally whether the Fund is currently
fully invested. Also advise whether the underwriters of the
Fund`s
common offering exercised their options to purchase additional
shares
to cover over-allotments and, if so, whether the underwriters
still
hold the shares so purchased.
Please advise us supplementally whether the Fund has a
strategy
concerning the duration of the Fund`s portfolio relative to the
auction dates of the preferred shares. Does the Fund have a
strategy
for dealing with rising interest rates or inverted yield curves?
Financial Highlights
Please advise us supplementally why the Fund will use
leverage
when it invests substantially in short-term debt.
Statement of Additional Information
Approval of Investment Advisory Agreement
This disclosure does not contain a reasonably detailed
discussion of the material factors that formed the basis for the
board of directors approving the investment advisory contract.
Please revise the disclosure accordingly. See Instruction to Item
18.13 of Form N-2.
Financial Statements
Please include updated financial statements in the
disclosure.
Please respond to this letter in the form of a pre-effective
amendment filed under Rule 472 of the Securities Act. Any
questions
you may have regarding the filing or this letter may be directed
to
me at 202.942.0686.
Sincerely,
Vincent J. Di Stefano
Senior Counsel
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