Correspondence 0001999371-24-004809 from GAMCO Global Gold, Natural Resources & Income Trust (GGN, GGN-PB) (CIK 0001313510) (GGN)
GAMCO Global Gold, Natural Resources & Income Trust (GGN, GGN-PB) (CIK 0001313510)
Date: April 15, 2024 · CIK: 0001313510 · Accession: 0001999371-24-004809
AI Filing Summary & Sentiment
File numbers found in text: 333-277179, 811-21698
Letter
VIA EDGAR Division of Investment Management 100 F Street N.E. Washington, DC 20549 RE: GAMCO Global Gold, Natural Resources & Income Trust (File Nos.: 333-277179; 811-21698
Dear Mr. Foor:
Thank you for your oral comments provided on March 25, 2024, regarding your review of the registration statement on Form N-2 filed on February 20, 2024 (the “Registration Statement”) by GAMCO Global Gold, Natural Resources & Income Trust (the “Fund”) with the U.S. Securities and Exchange Commission (the “SEC”). The Fund has considered your comments and authorized us to respond on its behalf as set forth below. Changes to the Registration Statement will be reflected in Pre-Effective Amendment No. 1 to the Registration Statement, which the Fund intends to file on or about the date hereof, and will be marked to show all changes made since the initial filing of the Registration Statement.
Your oral comments are summarized in bold to the best of our understanding, followed by the Fund’s responses. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Registration Statement.
Jeff Foor
April 15, 2024
Page 2
* * *
Investment Objectives and Policies
1. Please disclose the definition of "principally engaged" from the 80 percent investment policy.
The Fund has made the requested change.
Dividends and Distributions
2. Please inform the SEC’s staff (the “Staff”) whether the Fund intends to report a distribution rate. If the Fund does intend to report a distribution rate at any point prior to finalizing tax figures, the Staff notes that the Fund should disclose the estimated portion of the distribution rate that results from a return of capital. The Staff requests that any reports that would contain a distribution yield needs to be accompanied by the full return and/or SEC yield.
The Fund confirms that it will follow applicable SEC and Staff guidance to the extent that it reports a distribution rate.
* * * * * * *
Should you have any additional comments or concerns, please do not hesitate to contact me at (617) 573-4836.
Best regards,
/s/ Kenneth E. Burdon
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filename1.htm
Skadden,
Arps, Slate, Meagher & Flom llp
500 BOYLSTON STREET
Boston,
Massachusetts 02116
DIRECT DIAL
(617)
573-4836
DIRECT
FAX
(617)
305-4836
EMAIL ADDRESS
KENNETH.BURDON@SKADDEN.COM
TEL:
(617) 573-4800
FAX:
(617) 573-4822
www.skadden.com
FIRM/AFFILIATE
OFFICES
-----------
CHICAGO
HOUSTON
LOS
ANGELES
NEW
YORK
PALO
ALTO
WASHINGTON,
D.C.
WILMINGTON
-----------
BEIJING
BRUSSELS
FRANKFURT
HONG
KONG
LONDON
MUNICH
PARIS
SÃO
PAULO
SEOUL
SHANGHAI
SINGAPORE
TOKYO
TORONTO
April 15, 2024
VIA EDGAR
Jeff Foor
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549
RE:
GAMCO Global Gold, Natural Resources & Income Trust
(File Nos.: 333-277179; 811-21698
Dear Mr. Foor:
Thank you for your oral comments
provided on March 25, 2024, regarding your review of the registration statement on Form N-2 filed on February 20, 2024 (the “Registration
Statement”) by GAMCO Global Gold, Natural Resources & Income Trust (the “Fund”) with the U.S. Securities
and Exchange Commission (the “SEC”). The Fund has considered your comments and authorized us to respond on its behalf
as set forth below. Changes to the Registration Statement will be reflected in Pre-Effective Amendment No. 1 to the Registration Statement,
which the Fund intends to file on or about the date hereof, and will be marked to show all changes made since the initial filing of the
Registration Statement.
Your oral comments are summarized
in bold to the best of our understanding, followed by the Fund’s responses. Capitalized terms not otherwise defined herein have
the meanings ascribed to them in the Registration Statement.
Jeff Foor
April 15, 2024
Page 2
* * *
Investment Objectives and
Policies
1. Please disclose the definition of "principally engaged" from the 80 percent investment
policy.
The Fund has made the requested change.
Dividends and Distributions
2. Please inform the SEC’s staff (the “Staff”)
whether the Fund intends to report a distribution rate. If the Fund does intend to report a distribution rate at any point prior to finalizing
tax figures, the Staff notes that the Fund should disclose the estimated portion of the distribution rate that results from a return of
capital. The Staff requests that any reports that would contain a distribution yield needs to be accompanied by the full return and/or
SEC yield.
The Fund confirms
that it will follow applicable SEC and Staff guidance to the extent that it reports a distribution rate.
* * * * * * *
Should you have any additional comments
or concerns, please do not hesitate to contact me at (617) 573-4836.
Best regards,
/s/ Kenneth E. Burdon
Kenneth E. Burdon