SEC Company Response from RIVERNORTH OPPORTUNITIES FUND, INC. (RIV, RIV-PA) (CIK 0001501072) (RIV) — Nov 27, 2019
RIVERNORTH OPPORTUNITIES FUND, INC. (RIV, RIV-PA) (CIK 0001501072)
Date: Nov. 27, 2019 · CIK: 0001501072 · Accession: 0001398344-19-021446
AI Filing Summary & Sentiment
File numbers found in text: 333-225152, 811-22472
Letter
Securities and Exchange Commission Washington, D.C. 20549 Attention: Lauren Hamilton, Division of Investment Management Re: RiverNorth Opportunities Fund, Inc. (the “Fund”) File Nos. 333-225152; 811-22472
Dear Ms. Hamilton:
We are writing in response to a telephonic comment provided on November 26, 2019 with respect to Post-Effective Amendment No. 8 to the Fund’s registration statement filed on Form N-2 under the Securities Act of 1933, as amended (“Securities Act”), and Amendment No. 20 to the Fund’s registration statement filed under the Investment Company Act of 1940, as amended (“1940 Act”), on November 25, 2019 on behalf of the Fund, a closed-end investment company. The Fund has considered your comment and has authorized us to make the response discussed below on its behalf.
Comment 1. The Staff notes that the Fund’s registration statement does not contain a senior securities table. However, the Statement of Assets and Liabilities in the Fund’s annual report to shareholders dated July 31, 2019 lists $3,333 as “payable for borrowing.” If this item does not concern senior securities, please explain what this item represents.
Response: The Fund confirms that the payable for borrowing relates to the Fund’s credit facility, specifically representing a payable for the facility’s commitment fee that was incurred during the fiscal-year ended July 31, 2019. However, the Fund has not included the senior security table because as of the end of each of the Fund’s fiscal years since inception, the Fund did not have any borrowings under the Fund’s credit facility or any other senior security outstanding that would require disclosure in the table.
* * *
If you would like to discuss the response in further detail or if you have any questions, please feel free to contact me at 212-698-3526. Thank you.
Sincerely,
/s/Allison M. Fumai
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CORRESP
1
filename1.htm
1095 Avenue of the Americas
New York, NY 10036-6797
+1 212 698 3500 Main
+1 212 698 3599 Fax
www.dechert.com
Allison M. Fumai
allison.fumai@dechert.com
+1 212 698 3526 Direct
+1 212 698 3599 Fax
November 27, 2019
Securities and Exchange Commission
Washington, D.C. 20549
Attention: Lauren Hamilton, Division of Investment Management
Re: RiverNorth Opportunities Fund, Inc. (the “Fund”)
File Nos. 333-225152; 811-22472
Dear Ms. Hamilton:
We are writing in response
to a telephonic comment provided on November 26, 2019 with respect to Post-Effective Amendment No. 8 to the Fund’s registration
statement filed on Form N-2 under the Securities Act of 1933, as amended (“Securities Act”), and Amendment No. 20 to
the Fund’s registration statement filed under the Investment Company Act of 1940, as amended (“1940 Act”), on
November 25, 2019 on behalf of the Fund, a closed-end investment company. The Fund has considered your comment and has authorized
us to make the response discussed below on its behalf.
Comment 1. The Staff notes
that the Fund’s registration statement does not contain a senior securities table. However, the Statement of Assets and Liabilities
in the Fund’s annual report to shareholders dated July 31, 2019 lists $3,333 as “payable for borrowing.” If this
item does not concern senior securities, please explain what this item represents.
Response: The Fund
confirms that the payable for borrowing relates to the Fund’s credit facility, specifically representing a payable for the
facility’s commitment fee that was incurred during the fiscal-year ended July 31, 2019. However, the Fund has not included
the senior security table because as of the end of each of the Fund’s fiscal years since inception, the Fund did not have
any borrowings under the Fund’s credit facility or any other senior security outstanding that would require disclosure in
the table.
* * *
If you would like to discuss
the response in further detail or if you have any questions, please feel free to contact me at 212-698-3526. Thank you.
Sincerely,
/s/Allison M. Fumai
Allison M. Fumai