SEC Company Response from DoubleLine Funds Trust (CIK 0001480207) — Dec 23, 2025
DoubleLine Funds Trust (CIK 0001480207)
Date: Dec. 23, 2025 · CIK: 0001480207 · Accession: 0001193125-25-330499
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 811-22378, 811-23476
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Ms. Mindy Rotter Re: Sarbanes-Oxley Review of DoubleLine Funds
Dear Ms. Rotter:
Thank you for your oral comments provided on December 10, 2025, regarding the staff of the Securities and Exchange Commission’s (“SEC”) review, pursuant to the Sarbanes-Oxley Act of 2002, of the financial statements contained in the reports to shareholders, as well as related disclosures in the prospectuses and other filings of the DoubleLine funds listed on Appendix A attached hereto. The filings reviewed related to the fiscal year ended September 30, 2024 for the DoubleLine Yield Opportunities Fund (“DLY”) and to the fiscal year ended March 31, 2025 for the respective series of DoubleLine Funds Trust (the “Trust,” and each series, a “Fund”). Your comments are summarized below to the best of our understanding, followed by DLY’s or the Trust’s response, as applicable.
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1. Comment: The staff notes the attachment labeled “Item 405 Reg S-K” provided with DLY’s Form N-CEN filed on December 12, 2024. Please explain in correspondence the circumstances that led to the late filing, and please confirm in correspondence that procedures have been implemented to minimize the occurrence of such circumstances.
Response: DLY respectfully notes that the late filing was due to inadvertent administrative error. DLY understands the importance of timely filing the reports required by Section 16(a) of the Securities and Exchange Act of 1934, as amended, and believes it has taken measures to minimize the occurrence of such circumstances.
2. Comment: With respect to the Trust, the staff notes that the response to Item B.15, Exemptive Orders, was “no” in the Form N-CEN filed on June 10, 2025. Prior Form N-CENs filed with the SEC indicated that the Trust relied on exemptive order(s). Please review the response and determine whether it is accurate. If the response to Item B.15 is not accurate, please consider whether an amended Form N-CEN should be filed.
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Response: The Trust confirms that the response to Form N-CEN, Item B.15 is correct. The Trust’s prior responses to Item B.15 listed two exemptive orders, IC-29971 and IC-32534. The Trust respectfully notes that the Funds do not anticipate relying on these exemptive orders following the effective date of Rule 12d1-4 under the Investment Company Act of 1940, as amended.
3. Comment: With respect to DoubleLine Selective Credit Fund, the line graph presented for the DoubleLine Selective Credit Fund does not assume a $100,000 initial investment. Please explain in correspondence how the line graph conforms to Item 27A(d)(2), Instruction 1 of Form N-1A.
Response: The Trust confirms that it will update the disclosure referenced by the staff in future shareholder reports of DoubleLine Selective Credit Fund to reflect the then-current investment minimum.
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We hope the foregoing responses adequately address the staff’s comments. Should you have any further questions or comments, please do not hesitate to contact me at (617) 235-4614.
Respectfully submitted,
/s/ Michelle Huynh
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CORRESP 1 filename1.htm CORRESP ROPES & GRAY LLP PRUDENTIAL TOWER 800 BOYLSTON STREET BOSTON, MA 02199-3600 WWW.ROPESGRAY.COM Michelle Huynh December 23, 2025 T +1 617 235 4614 michelle.huynh@ropesgray.com VIA EDGAR Division of Investment Management Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Ms. Mindy Rotter Re: Sarbanes-Oxley Review of DoubleLine Funds Dear Ms. Rotter: Thank you for your oral comments provided on December 10, 2025, regarding the staff of the Securities and Exchange Commission’s (“SEC”) review, pursuant to the Sarbanes-Oxley Act of 2002, of the financial statements contained in the reports to shareholders, as well as related disclosures in the prospectuses and other filings of the DoubleLine funds listed on Appendix A attached hereto. The filings reviewed related to the fiscal year ended September 30, 2024 for the DoubleLine Yield Opportunities Fund (“DLY”) and to the fiscal year ended March 31, 2025 for the respective series of DoubleLine Funds Trust (the “Trust,” and each series, a “Fund”). Your comments are summarized below to the best of our understanding, followed by DLY’s or the Trust’s response, as applicable. * * * * * * 1. Comment: The staff notes the attachment labeled “Item 405 Reg S-K” provided with DLY’s Form N-CEN filed on December 12, 2024. Please explain in correspondence the circumstances that led to the late filing, and please confirm in correspondence that procedures have been implemented to minimize the occurrence of such circumstances. Response: DLY respectfully notes that the late filing was due to inadvertent administrative error. DLY understands the importance of timely filing the reports required by Section 16(a) of the Securities and Exchange Act of 1934, as amended, and believes it has taken measures to minimize the occurrence of such circumstances. 2. Comment: With respect to the Trust, the staff notes that the response to Item B.15, Exemptive Orders, was “no” in the Form N-CEN filed on June 10, 2025. Prior Form N-CENs filed with the SEC indicated that the Trust relied on exemptive order(s). Please review the response and determine whether it is accurate. If the response to Item B.15 is not accurate, please consider whether an amended Form N-CEN should be filed. - 2 - Response: The Trust confirms that the response to Form N-CEN, Item B.15 is correct. The Trust’s prior responses to Item B.15 listed two exemptive orders, IC-29971 and IC-32534. The Trust respectfully notes that the Funds do not anticipate relying on these exemptive orders following the effective date of Rule 12d1-4 under the Investment Company Act of 1940, as amended. 3. Comment: With respect to DoubleLine Selective Credit Fund, the line graph presented for the DoubleLine Selective Credit Fund does not assume a $100,000 initial investment. Please explain in correspondence how the line graph conforms to Item 27A(d)(2), Instruction 1 of Form N-1A. Response: The Trust confirms that it will update the disclosure referenced by the staff in future shareholder reports of DoubleLine Selective Credit Fund to reflect the then-current investment minimum. * * * * * * We hope the foregoing responses adequately address the staff’s comments. Should you have any further questions or comments, please do not hesitate to contact me at (617) 235-4614. Respectfully submitted, /s/ Michelle Huynh Michelle Huynh cc: Ronald R. Redell Carolyn Liu-Hartman, Esq. Jeremy C. Smith, Esq. Garrett Sweeney, Esq. - 3 - Appendix A File No. Series Name Registrant Name 811-22378 DoubleLine Core Fixed Income Fund DoubleLine Funds Trust 811-22378 DoubleLine Emerging Markets Fixed Income Fund DoubleLine Funds Trust 811-22378 DoubleLine Emerging Markets Local Currency Bond Fund DoubleLine Funds Trust 811-22378 DoubleLine Flexible Income Fund DoubleLine Funds Trust 811-22378 DoubleLine Floating Rate Fund DoubleLine Funds Trust 811-22378 DoubleLine Global Bond Fund DoubleLine Funds Trust 811-22378 DoubleLine Income Fund DoubleLine Funds Trust 811-22378 DoubleLine Infrastructure Income Fund DoubleLine Funds Trust 811-22378 DoubleLine Long Duration Total Return Bond Fund DoubleLine Funds Trust 811-22378 DoubleLine Low Duration Bond Fund DoubleLine Funds Trust 811-22378 DoubleLine Low Duration Emerging Markets Fixed Income Fund DoubleLine Funds Trust 811-22378 DoubleLine Shiller Enhanced CAPE DoubleLine Funds Trust 811-22378 DoubleLine Shiller Enhanced International CAPE DoubleLine Funds Trust 811-22378 DoubleLine Strategic Commodity Fund DoubleLine Funds Trust 811-22378 DoubleLine Total Return Bond Fund DoubleLine Funds Trust 811-22378 DoubleLine Selective Credit Fund DoubleLine Funds Trust 811-23476 DoubleLine Yield Opportunities Fund DoubleLine Yield Opportunities Fund