SEC Company Response from abrdn Global Dynamic Dividend Fund (AGD) (CIK 0001362481) (AGD) — Sep 27, 2022
abrdn Global Dynamic Dividend Fund (AGD) (CIK 0001362481)
Date: Sept. 27, 2022 · CIK: 0001362481 · Accession: 0001104659-22-103448
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-266796, 333-266798, 333-266799
Letter
September 27, 2022
VIA EDGAR
Mr. Chad Eskildsen
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Ms. Ashley Vroman-Lee
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Response to Comments on the proxy statements/prospectuses filed on Form N-14 (each, a “Proxy Statement/Prospectus” and collectively, “Proxy Statements/Prospectuses”) by the following funds (each an “Acquiring Fund” and, collectively the “Acquiring Funds”) on August 11, 2022:
abrdn Global Dynamic Dividend Fund
Securities Act File No. 333-266796
abrdn Global Infrastructure Income Fund
Securities Act File No. 333-266798
abrdn Income Credit Strategies Fund
Securities Act File No. 333-266799
Mr. Eskildsen and Ms. Vroman-Lee:
This letter responds to comments on the Proxy Statements/Prospectuses with respect to the proposed reorganizations as shown below that the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) provided telephone conversation with Ashley Vroman-Lee and Brooke Clark of Dechert LLP on September 27, 2022.
Acquired Funds (each an “Acquired Fund”)
Acquiring Funds
Delaware Enhanced Global Dividend and Income Fund
into
abrdn Global Dynamic Dividend Fund
Delaware Investments® Dividend and Income Fund, Inc.
Macquarie Global Infrastructure Income Fund Inc.
into
abrdn Global Infrastructure Income Fund
Delaware Ivy High Income Opportunities Fund
into
abrdn Income Credit Strategies Fund
On behalf of the Acquiring Funds, your comments and our responses to them are provided below. All defined terms in this letter have the same meaning as in the Proxy Statements/Prospectuses, except as defined herein.
Comments applicable to each Proxy Statement/Prospectus
Comment 1: With respect to previous Comment 3 provided on September 2, 2022, please confirm any material considerations adverse to the Reorganization proposal are disclosed and fairly described. Please see Items 3(b) and 4(a) of Form N-14 and Item 22(c)(11) of Schedule 14A.
Response: Additional disclosure has been added in response to the Staff’s comment.
Comment 2: With respect to previous Comment 4 provided on September 2, 2022, and with respect to the disclosure discussing the possibility of converting to an open-end fund, please revise the disclosure to reflect that the Acquiring Funds have no plans to convert to an open-end fund structure or please consider removing the disclosure.
Response: The disclosure has been removed.
* * * * *
Should you have any questions concerning the above, please call the undersigned at (202) 261-3360.
Very truly yours,
/s/ Thomas C. Bogle
Show Raw Text
CORRESP 1 filename1.htm September 27, 2022 VIA EDGAR Mr. Chad Eskildsen Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Ms. Ashley Vroman-Lee Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Response to Comments on the proxy statements/prospectuses filed on Form N-14 (each, a “Proxy Statement/Prospectus” and collectively, “Proxy Statements/Prospectuses”) by the following funds (each an “Acquiring Fund” and, collectively the “Acquiring Funds”) on August 11, 2022: abrdn Global Dynamic Dividend Fund Securities Act File No. 333-266796 abrdn Global Infrastructure Income Fund Securities Act File No. 333-266798 abrdn Income Credit Strategies Fund Securities Act File No. 333-266799 Mr. Eskildsen and Ms. Vroman-Lee: This letter responds to comments on the Proxy Statements/Prospectuses with respect to the proposed reorganizations as shown below that the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) provided telephone conversation with Ashley Vroman-Lee and Brooke Clark of Dechert LLP on September 27, 2022. Acquired Funds (each an “Acquired Fund”) Acquiring Funds Delaware Enhanced Global Dividend and Income Fund into abrdn Global Dynamic Dividend Fund Delaware Investments® Dividend and Income Fund, Inc. Macquarie Global Infrastructure Income Fund Inc. into abrdn Global Infrastructure Income Fund Delaware Ivy High Income Opportunities Fund into abrdn Income Credit Strategies Fund On behalf of the Acquiring Funds, your comments and our responses to them are provided below. All defined terms in this letter have the same meaning as in the Proxy Statements/Prospectuses, except as defined herein. Comments applicable to each Proxy Statement/Prospectus Comment 1: With respect to previous Comment 3 provided on September 2, 2022, please confirm any material considerations adverse to the Reorganization proposal are disclosed and fairly described. Please see Items 3(b) and 4(a) of Form N-14 and Item 22(c)(11) of Schedule 14A. Response: Additional disclosure has been added in response to the Staff’s comment. Comment 2: With respect to previous Comment 4 provided on September 2, 2022, and with respect to the disclosure discussing the possibility of converting to an open-end fund, please revise the disclosure to reflect that the Acquiring Funds have no plans to convert to an open-end fund structure or please consider removing the disclosure. 1 Response: The disclosure has been removed. * * * * * Should you have any questions concerning the above, please call the undersigned at (202) 261-3360. Very truly yours, /s/ Thomas C. Bogle Thomas C. Bogle 2