SEC Company Response from Fidelity Central Investment Portfolios LLC (CIK 0001303459) — Mar 26, 2020
Fidelity Central Investment Portfolios LLC (CIK 0001303459)
Date: March 26, 2020 · CIK: 0001303459 · Accession: 0001379491-20-001054
AI Filing Summary & Sentiment
File numbers found in text: 811-21667
Letter
COMMENTS RECEIVED ON 02/18/2020
FROM EDWARD BARTZ
FIDELITY CENTRAL INVESTMENT PORTFOLIOS LLC (File No. 811-21667)
Fidelity High Income Central Fund
AMENDMENT NO. 55
1)
“Investment Details” (prospectus)
“Principal Investment Strategies”
C:
The Staff requests we disclose the maturity policy for the fund’s debt securities.
R:
The fund does not have a principal investment strategy of investing in securities with a particular maturity. Accordingly, we have not modified disclosure.
2)
“Investment Details” (prospectus)
“Principal Investment Strategies”
C:
The Staff requests we explain whether there are any investments in contingent convertible securities
and, if so, include appropriate strategy and risk disclosure.
R:
Investing in contingent convertible securities is not a principal investment strategy for the fund.
Accordingly, we have not modified the disclosure.
3)
“Investment Details” (prospectus)
“Principal Investment Strategies”
C:
The Staff questions whether the fund will invest in emerging markets securities and, if so, asks that we include appropriate strategy and risk disclosure.
R:
Although the fund may invest in securities of foreign issuers, including emerging markets securities, investments in emerging markets are not a principal investment strategy of the fund. As a result, the fund believes that the current strategy and risk disclosure is appropriate.
4)
“Investment Details” (prospectus)
“Principal Investment Risks”
C:
Since the fund’s principal investment strategy states that the fund emphasizes junk bonds, the Staff requests we add a separate junk bond risk for lower-quality securities.
R:
We believe the risks associated with investing in junk bonds are described in “Issuer−Specific Changes” and, therefore, the addition of a separate risk factor for this type of investment would be duplicative.
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CORRESP 1 filename1.htm COMMENTS RECEIVED ON 02/18/2020 FROM EDWARD BARTZ FIDELITY CENTRAL INVESTMENT PORTFOLIOS LLC (File No. 811-21667) Fidelity High Income Central Fund AMENDMENT NO. 55 1) “Investment Details” (prospectus) “Principal Investment Strategies” C: The Staff requests we disclose the maturity policy for the fund’s debt securities. R: The fund does not have a principal investment strategy of investing in securities with a particular maturity. Accordingly, we have not modified disclosure. 2) “Investment Details” (prospectus) “Principal Investment Strategies” C: The Staff requests we explain whether there are any investments in contingent convertible securities and, if so, include appropriate strategy and risk disclosure. R: Investing in contingent convertible securities is not a principal investment strategy for the fund. Accordingly, we have not modified the disclosure. 3) “Investment Details” (prospectus) “Principal Investment Strategies” C: The Staff questions whether the fund will invest in emerging markets securities and, if so, asks that we include appropriate strategy and risk disclosure. R: Although the fund may invest in securities of foreign issuers, including emerging markets securities, investments in emerging markets are not a principal investment strategy of the fund. As a result, the fund believes that the current strategy and risk disclosure is appropriate. 4) “Investment Details” (prospectus) “Principal Investment Risks” C: Since the fund’s principal investment strategy states that the fund emphasizes junk bonds, the Staff requests we add a separate junk bond risk for lower-quality securities. R: We believe the risks associated with investing in junk bonds are described in “Issuer−Specific Changes” and, therefore, the addition of a separate risk factor for this type of investment would be duplicative.