Correspondence 0001104659-23-062647 from Virtus Stone Harbor Emerging Markets Income Fund (EDF) (CIK 0001501103) (EDF)
Virtus Stone Harbor Emerging Markets Income Fund (EDF) (CIK 0001501103)
Date: May 19, 2023 · CIK: 0001501103 · Accession: 0001104659-23-062647
AI Filing Summary & Sentiment
File numbers found in text: 333-271026
Letter
Securities and Exchange Commission stephanie.capistron@dechert.com Division of Investment Management +1 617 728 7127 Direct Washington, D.C. 20549 Attn: Ms. Deborah L. O’Neal Re: Virtus Stone Harbor Emerging Markets Income Fund (the “Registrant”) (File No. 333-271026)
Dear Ms. O’Neal:
This letter responds to the comments you provided to me on May 1, 2023 with respect to your review of the Registrant’s preliminary Registration Statement filed on Form N-14 under the Securities Act of 1933, as amended, on March 31, 2023 in connection with the Reorganization of the Stone Harbor Emerging Markets Total Income Fund with and into the Registrant. We have reproduced your comments below, followed by the Registrant’s responses. Capitalized terms have the meanings attributed to such terms in the preliminary Registration Statement.
Comment 1. In the third paragraph on page 17, please confirm and disclose whether the Acquiring Fund and the Acquired Fund paid a return of capital in 2022.
Response 1. The Registrant has added the following disclosure in response to this comment:
During 2022, a portion of each Fund’s total distributions consisted of a return of capital.
Comment 2. On page 21, please consider highlighting the following disclosure in bold or italicized font: “The Acquiring Fund’s Declaration of Trust and the Bylaws include provisions that could limit the ability of other entities or persons to acquire control of the Fund or to convert the Fund to open-end status.”
Response 2. The Registrant has incorporated this comment.
* * *
We believe that the foregoing has been responsive to the Staff’s comments. Please call the undersigned at (617) 728-7127 if you wish to discuss this correspondence further.
Very truly yours,
/s/ Stephanie A. Capistron
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One International Place
40th Floor
100 Oliver Street
Boston, MA 02110-2605
+1 617 728 7100 Main
+1 617 426 6567 Fax
www.dechert.com
May 19, 2023
Stephanie Capistron
Securities and Exchange Commission
stephanie.capistron@dechert.com
Division of Investment Management
+1 617 728 7127 Direct
100 F Street, NE
Washington, D.C. 20549
Attn: Ms. Deborah L. O’Neal
Re: Virtus Stone Harbor Emerging
Markets Income Fund (the “Registrant”)
(File No. 333-271026)
Dear Ms. O’Neal:
This letter responds to the comments you provided
to me on May 1, 2023 with respect to your review of the Registrant’s preliminary Registration Statement filed on Form N-14
under the Securities Act of 1933, as amended, on March 31, 2023 in connection with the Reorganization of the Stone Harbor Emerging
Markets Total Income Fund with and into the Registrant. We have reproduced your comments below, followed by the Registrant’s responses.
Capitalized terms have the meanings attributed to such terms in the preliminary Registration Statement.
Comment 1.
In the third paragraph on page 17, please confirm and disclose whether the Acquiring Fund and the Acquired Fund paid a return of capital in 2022.
Response
1.
The Registrant has added the following disclosure in response to this comment:
During 2022, a portion of each Fund’s
total distributions consisted of a return of capital.
Comment 2.
On page 21, please consider highlighting the following disclosure in bold or italicized font: “The Acquiring Fund’s Declaration of Trust and the Bylaws include provisions that could limit the ability of other entities or persons to acquire control of the Fund or to convert the Fund to open-end status.”
Response
2.
The Registrant has incorporated this comment.
* *
*
We believe that the foregoing has been
responsive to the Staff’s comments. Please call the undersigned at (617) 728-7127 if you wish to discuss this correspondence
further.
Very truly yours,
/s/ Stephanie A. Capistron
Stephanie A. Capistron