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Correspondence 0001193125-24-244111 from Virtus Stone Harbor Emerging Markets Income Fund (EDF) (CIK 0001501103) (EDF)

Virtus Stone Harbor Emerging Markets Income Fund (EDF) (CIK 0001501103)
Date: Oct. 25, 2024 · CIK: 0001501103 · Accession: 0001193125-24-244111

AI Filing Summary & Sentiment

File numbers found in text: 811-22473

Date
October 25, 2024
Author
/s/ Kathryn Santoro
Form
CORRESP
Company
Virtus Stone Harbor Emerging Markets Income Fund (EDF) (CIK 0001501103)

Letter

Division of Investment Management Washington, D.C. 20549 Re: Virtus Stone Harbor Emerging Markets Income Fund (the “Registrant”) Investment Company Act File No. 811-22473 Registration Statement Filing on Form N-2

Dear Mses. O’Neal, DiAngelo Fettig and Mr. Manion:

This letter responds to comments provided by telephone on October 15, 2024 and October 23, 2024, regarding the pre-effective amendment to the registration statement on Form N-2 (the “Registration Statement”) relating to the registration of additional shares of the Registrant, as filed with the Securities and Exchange Commission on October 11, 2024. The Staff’s comments, as we understand them, and the Registrant’s responses are below.

Unless otherwise noted, capitalized terms have the same meanings as used in the Registration Statement.

1. Staff Comment: Please incorporate by reference or present the Registrant’s financial highlights for the last ten fiscal years.

Response: The requested changes have been made.

2. Staff Comment: Please include the consent of the Registrant’s independent registered public accountant for the additionally incorporated financial highlights.

Response: The consent has been included.

3. Staff Comment: Please request revisions to the auditor’s consent to correct the filing type and Securities Act file number.

Response: The requested revisions have been communicated to the auditor.

4. Staff Comment: Please incorporate by reference the Registrant’s semi-annual report for the six-month period ending May 31, 2024.

Response: The requested changes have been made.

Please call me at (860) 503-1116 should you have additional comments or questions.

Respectfully,
/s/ Kathryn Santoro

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CORRESP
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CORRESP

 101
Munson Street, Greenfield, MA 01301 | 866.270.7788 | Virtus.com

 October 25, 2024

Ms. Deborah O’Neal

 Mr. David Manion

Ms. Christina DiAngelo Fettig

 Division of Investment Management

U.S. Securities and Exchange Commission

 100 F Street, NE

Washington, D.C. 20549

Re:
 Virtus Stone Harbor Emerging Markets Income Fund (the “Registrant”)

 
 Investment Company Act File No. 811-22473

 
 Registration Statement Filing on Form N-2

Dear Mses. O’Neal, DiAngelo Fettig and Mr. Manion:

 This letter responds to
comments provided by telephone on October 15, 2024 and October 23, 2024, regarding the pre-effective amendment to the registration statement on Form N-2 (the
“Registration Statement”) relating to the registration of additional shares of the Registrant, as filed with the Securities and Exchange Commission on October 11, 2024. The Staff’s comments, as we understand them, and the
Registrant’s responses are below.

 Unless otherwise noted, capitalized terms have the same meanings as used in the Registration Statement.

1.
 Staff Comment: Please incorporate by reference or present the Registrant’s financial highlights for the
last ten fiscal years.

 Response: The requested changes have been made.

2.
 Staff Comment: Please include the consent of the Registrant’s independent registered public accountant for
the additionally incorporated financial highlights.

 Response: The consent has been included.

3.
 Staff Comment: Please request revisions to the auditor’s consent to correct the filing type and Securities
Act file number.

 Response: The requested revisions have been communicated to the auditor.

4.
 Staff Comment: Please incorporate by reference the Registrant’s semi-annual report for the six-month period ending May 31, 2024.

 Response: The requested changes have been
made.

 Please call me at (860) 503-1116 should you have additional comments or questions.

Respectfully,

 /s/ Kathryn Santoro

Kathryn Santoro

 Vice President, Secretary and Chief Legal Officer