Correspondence 0000894189-24-002273 from LOCORR INVESTMENT TRUST (CIK 0001506768)
LOCORR INVESTMENT TRUST (CIK 0001506768)
Date: April 5, 2024 · CIK: 0001506768 · Accession: 0000894189-24-002273
AI Filing Summary & Sentiment
File numbers found in text: 333-171360, 811-22509
Letter
Office of Disclosure and Review Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: LoCorr Investment Trust – LoCorr Hedged Core Fund (File Nos. 811-22509, 333-171360)
Dear Ms. Im-Tang:
On January 9, 2024, LoCorr Investment Trust (the "Registrant" or the “Trust”), on behalf of LoCorr Hedged Core Fund (the "Fund"), a new series of the Registrant, filed Post-Effective Amendment No. 53 to its Registration Statement under the Securities Act of 1933 on Form N-1A. Bernard Nolan and you provided the following comments on March 1, 2024 to the Registration Statement by phone to Andrew Davalla. Please find below a summary of those comments and the Registrant's responses, which the Registrant has authorized Thompson Hine LLP to make on behalf of the Registrant.
General Comments
Prospectus
Comment 1. Please provide ticker once available.
Response. The tickers have been provided. Please see prospectus attached hereto as an exhibit.
Comment 2. With respect to Footnote 4 to the fee table, please clarify refer to total assets or net assets.
Response. The disclosure has been revised as follows:
Generally, the management fees and performance fees of the CTAs included in the Swap and Commodity Pool may range up to 1.50% of the Fund’s net assets and up to 20% of returns. Given the expected allocations, it is expected that management fees will be 0.75% of net assets and up to 20% of the returns, respectively.
April 5, 2024
Page 2
Comment 3. Please confirm that the Registrant does not anticipate and acquired fund fees and expenses for the first fiscal period.
Response. The Registrant does not anticipate that the Fund will incur any estimated acquired fund fees and expenses for its first fiscal period. It is expected that the Fund will invest cash balances in a deposit account with its custodian.
Comment 4. With respect to Footnote 5, please revise to state if the fund may make repayment only if such repayment does not cause the Fund’s expense ratio to exceed both the expense cap at the time of the waiver and the current expense cap.
Response. The disclosure has been revised as follows:
These fee waivers and expense reimbursements are subject to possible recoupment from the Fund within three years following the date on which the fee waiver or expense reimbursement occurred, if the Fund is able to make the repayment without exceeding the expense limitation at time of waiver and its current expense limitations and the repayment is approved by the Board of Trustees.
Comment 5. Please provide a completed fee table and expense example in your responses.
Response. Please see attached prospectus.
Comment 6. Please clarify if securities held by the CFC may also be leveraged.
Response. Outside of the leverage inherent in futures contracts, the CFC will not be otherwise directly leveraged.
Comment 7. Please clarify that the Fund complies with the Investment Company Act of 1940 (the “Act”) requirements for capital structure and leverage on an aggregate basis with its CFC such that the Fund treats the CFC’s debt as its own for the purposes of compliance with Section 18 of the Act.
Response. The following disclosure has been added:
The Fund treats obligations of the Subsidiary as its own and, on an aggregate basis with the Subsidiary, complies with the requirements of Section 18 of the 1940 Act regarding capital structure and leverage.
April 5, 2024
Page 3
Comment 8. Please disclose that any adviser to the subsidiary complies with provisions to Section 15 of the Act regarding advisory agreements and any advisory agreement with the subsidiary is added as an exhibit to the Registration Statement.
Response. The following disclosure has been added:
Any advisory or subadvisory agreement with respect to the Subsidiary meets the requirements for advisory agreements under Section 15 of the 1940 Act.
Comment 9. Please disclose that the Subsidiary complies with the affiliated transaction and custody provisions under Section 17 of the Act.
Response. The following disclosure has been added:
The Subsidiary complies with the affiliated transaction and custody provisions under Section 17 of the 1940 Act.
Comment 10. Please confirm that the subsidiary and its board of directors will agree to inspection of books and records under Section 31 of the Act.
Response. The Registrant so confirms.
Comment 11. Please include any management fees, including any performance fees, for the subsidiary in the Management Fee in the fee table and include other subsidiary expenses under Other Expenses in the fee table.
Response. The Registrant notes that such fees, if incurred, are appropriately provided for in the Fund’s fee table.
Comment 12. Please disclose that the Fund does no intent to create or invest to gain primary control in an entity primarily engaged in investment activities other than its wholly-owned subsidiary.
Response. The following disclosure has been added:
The Fund does not intent to create or invest to gain primary control in an entity primarily engaged in investment activities other than the Subsidiary.
Comment 13: Please clarify what is meant by the reference to “traditional investment process” in the Adviser’s Investment Process disclosure.
April 5, 2024
Page 4
Response: The disclosure has been revised as follows:
The Adviser replaces a sub-adviser when its returns are below expectations or it deviates from its traditional investment process with respect to changes in investment strategy.
Comment 14: With respect to the disclosure for Graham Capital Management and R.G. Niederhoffer Capital Management, please clarify what is meant “absolute returns and “stable absolute returns,” respectively.
Response: The following disclosure has been added:
“(that is, a strategy which seeks to produce positive returns over time regardless of market movements.)”
Comment 15: Please present the most important principal investment risks first and after the most important risks have been disclosed the Fund may revert back to alphabetical order.
Response: The Registrant respectfully declines to make the requested revision.
Comment 16: With respect to Derivatives Risk, please consider revising to provide more details regarding the risks of specific derivatives used by the Fund.
Response: The disclosure has been revised as follows:
• Derivatives Risk: Futures, options and swaps involve risks different from, or possibly greater than, the risks associated with investing directly in securities and other traditional investments. These risks include (i) the risk that the counterparty to a derivative transaction may not fulfill its contractual obligations; (ii) risk of mispricing or improper valuation; and (iii) the risk that changes in the value of the derivative may not correlate perfectly with the underlying asset, rate or index. The use of derivatives subject to regulation by the Commodity Futures Trading Commission (“CFTC”) by Underlying Funds may be subject to certain rules of the CFTC. Derivative prices are highly volatile and may fluctuate substantially during a short period of time. Such prices are influenced by numerous factors that affect the markets, including, but not limited to: changing supply and demand relationships; government programs and policies; national and international political and economic events, changes in interest rates, inflation and deflation and changes in supply and demand relationships.
•Futures and Forwards Risk. The primary risks associated with the use of forward and futures contracts, which may adversely affect the Fund’s net asset value (“NAV”)
April 5, 2024
Page 5
and total return, are (a) the imperfect correlation between the change in market value of the instruments held by the Fund or an Underlying Fund and the price of the forward or futures contract; (b) possible lack of a liquid secondary market for a forward or futures contract and the resulting inability to close a forward or futures contract when desired; (c) losses caused by unanticipated market movements, which are potentially unlimited; (d) the inability to predict correctly the direction of securities prices, interest rates, currency exchange rates and other economic factors; (e) the possibility that the counterparty will default in the performance of its obligations; and (f) if the Fund or Underlying Fund has insufficient cash, it may have to sell securities from its portfolio to meet daily variation margin requirements, and the Fund or Underlying Fund may have to sell securities at a time when it may be disadvantageous to do so.
•Options Risk. There are risks associated with the sale and purchase of call and put options. As the buyer of a put or call option, the Fund risks losing the entire premium invested in the option if the Fund does not exercise the option. Because option premiums paid by the Fund indirectly through Underlying Funds are small in relation to the market value of the investments underlying the options, buying and selling put and call options can be more speculative than investing directly in securities. Purchased put options may decline in value due to changes in value of the underlying reference asset.
•Swap Risk. Swap agreements are subject to the risk that the counterparty to the swap will default on its obligation to pay the Fund and the risk that the Fund will not be able to meet its obligations to pay the counterparty to the swap. In addition, there is the risk that a swap may be terminated by the Fund or the counterparty in accordance with its terms. If a swap were to terminate, the Fund may be unable to implement its investment strategies and the Fund may not be able to seek to achieve its investment objective.
Comment 17: If investing in emerging markets, please define emerging markets and disclose how investing and risks are different than foreign risks.
Response: The following disclosure has been added:
Through its Managed Futures and Commodities strategies, the Fund will have exposure to underlying assets in the U.S. as well as foreign and emerging markets. The Fund defines emerging markets as those that are found in the MSCI Emerging Markets Index.
Comment 18: Please clarify if frequent trading is a principal investment strategy, and if so, please disclose in the principal investment strategy section.
April 5, 2024
Page 6
Response: The Registrant does not believe frequent trading will be a principal investment strategy for the Fund.
Comment 19: Please reconcile any differences in the Managed Futures strategy disclosure in Items 4 and 10.
Response: The disclosure in Item 10 has been revised as follows:
The Managed Futures strategy is designed to produce capital appreciation by capturing returns related to the commodity and financial markets by investing long or short in: (i) futures, (ii) forwards, (iii) options, (iv) spot contracts, or (v) swaps, each of which may be tied to (a) currencies including Bitcoin and Ethereum cryptocurrencies, (b) interest rates, (c) stock market indices, (d) energy resources, (e) metals or (f) agricultural products.
Comment 20: Please define “Index” as described in the disclosure for the Commodities Futures strategy.
Response: The disclosure has been revised as follows:
To the extent the Adviser is utilizing derivatives to gain exposure to managers, it is anticipated that the Fund uses a total return swap (the "Swap"), a type of derivative instrument based on a customized index (the "Index") designed to replicate the aggregate returns of the managers selected by the Adviser.
Comment 21: With respect to the description of the investment process for R.G. Niederhoffer, please clarify what is meant by “behavioral biases.”
Response: The Registrant respectfully declines to revise the existing disclosure.
Comment 22: Please include LIBOR transition risk, if applicable, and how the successor reference rate may impact the value of such securities.
Response: The Fund’s adviser confirms that LIBOR risk is not a principal risk of the Fund.
Comment 23: Please revise references to “Funds” in the Credit Risk and Wholly-Owned Subsidiary Risk disclosures and correct the typo “Funs” in Market Risk.
Response: The requested revisions have been made.
Comment 24: Please delete the duplicative Covid-19 sentence in Market Risk.
April 5, 2024
Page 7
Response: The requested revisions has been made.
Comment 25: Please include Preferred Stock Risk in the summary section or delete if not applicable.
Response: The risk has been deleted.
Comment 26: Please add “Section” prior to the reference to 1256 futures contracts.
Response: The requested revision has been made.
Comment 27: Please add a reference to the Fund’s website in the Portfolio Holdings Disclosure section.
Response: The requested revision has been made.
Comment 28: Please complete the assets under management disclosures for the subadvisers.
Response: The requested revisions has been made.
Comment 29: Please consider the Foreign Risk disclosure to disclose risks associated with the value of Underlying Funds that hold foreign securities.
Response: The Registrant respectfully declines to amend the existing disclosure and notes that Underlying Funds with foreign holdings are not a principal investment strategy for the Fund.
Comment 30: Please add the date of the commencement of the Fund’s operations in the Financial Highlights disclosure.
Response: The disclosure has been revised as follows:
The Fund only recently commenced operations in May 2024.
Comment 31: Please revise the reference to registered representatives and complete the omitted disclosures in the Baird sales charge waiver section.
Response: The requested revisions have been made.
Comment 32: Please define “OPCO” in the Oppenheimer and Co Inc. sales charge waiver disclosure.
Response: The requested revisions have been made.
April 5, 2024
Page 8
SAI
Comment 33: Please provide additional disclosure for parent companies of Graham Capital Management and Nuveen Asset Management.
Response: The following disclosure has been added:
Graham: The general partner of GCM is KGT, Inc., a Delaware corporation of which Kenneth G. Tropin (the firm’s Chairman and Founder) is the President and ultimate sole shareholder. The limited partner of GCM is KGT Investment Partners L.P., a Delaware limited partnership of which KGT, Inc. is also a general partner and in which Mr. Tropin and members of his immediate family are significant beneficial owners. Dyal Capital, formerly a Neuberger Berman company and, as of 2021, a division of Blue Owl Capital Inc., owns an indirect minority interest in the firm.
Nuveen: Nuveen, LLC is a subsidiary and the investment manager of Teachers Insurance and Annuity Association of America (TIAA), a leading financial services provider serving over 5 million individual participants and 15,000 institutions worldwide as of March 31, 2023.
Comment 34: Please provide the Fund’s website in the Proxy Voting Policies disclosure.
Response: The requested additional disclosure has been provided.
Comment 35: Please provide the Other Accounts information for the portfolio managers as of a recent date.
Response: Information as of March 31, 2024 will be provided in the post-effective amendment.
Comment 36: Please provide the subsidiary’s name and delete references to Subsidiaries, unless applicable.
Response: The requested revisions have been made. Supplementally, the Subsidiary is named LCHC Fund Limited.
Comment 37: Please disclose that the Fund
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Document
April 5, 2024
Ms. Soo Im-Tang
Office of Disclosure and Review
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: LoCorr Investment Trust – LoCorr Hedged Core Fund (File Nos. 811-22509, 333-171360)
Dear Ms. Im-Tang:
On January 9, 2024, LoCorr Investment Trust (the "Registrant" or the “Trust”), on behalf of LoCorr Hedged Core Fund (the "Fund"), a new series of the Registrant, filed Post-Effective Amendment No. 53 to its Registration Statement under the Securities Act of 1933 on Form N-1A. Bernard Nolan and you provided the following comments on March 1, 2024 to the Registration Statement by phone to Andrew Davalla. Please find below a summary of those comments and the Registrant's responses, which the Registrant has authorized Thompson Hine LLP to make on behalf of the Registrant.
General Comments
Prospectus
Comment 1. Please provide ticker once available.
Response. The tickers have been provided. Please see prospectus attached hereto as an exhibit.
Comment 2. With respect to Footnote 4 to the fee table, please clarify refer to total assets or net assets.
Response. The disclosure has been revised as follows:
Generally, the management fees and performance fees of the CTAs included in the Swap and Commodity Pool may range up to 1.50% of the Fund’s net assets and up to 20% of returns. Given the expected allocations, it is expected that management fees will be 0.75% of net assets and up to 20% of the returns, respectively.
April 5, 2024
Page 2
Comment 3. Please confirm that the Registrant does not anticipate and acquired fund fees and expenses for the first fiscal period.
Response. The Registrant does not anticipate that the Fund will incur any estimated acquired fund fees and expenses for its first fiscal period. It is expected that the Fund will invest cash balances in a deposit account with its custodian.
Comment 4. With respect to Footnote 5, please revise to state if the fund may make repayment only if such repayment does not cause the Fund’s expense ratio to exceed both the expense cap at the time of the waiver and the current expense cap.
Response. The disclosure has been revised as follows:
These fee waivers and expense reimbursements are subject to possible recoupment from the Fund within three years following the date on which the fee waiver or expense reimbursement occurred, if the Fund is able to make the repayment without exceeding the expense limitation at time of waiver and its current expense limitations and the repayment is approved by the Board of Trustees.
Comment 5. Please provide a completed fee table and expense example in your responses.
Response. Please see attached prospectus.
Comment 6. Please clarify if securities held by the CFC may also be leveraged.
Response. Outside of the leverage inherent in futures contracts, the CFC will not be otherwise directly leveraged.
Comment 7. Please clarify that the Fund complies with the Investment Company Act of 1940 (the “Act”) requirements for capital structure and leverage on an aggregate basis with its CFC such that the Fund treats the CFC’s debt as its own for the purposes of compliance with Section 18 of the Act.
Response. The following disclosure has been added:
The Fund treats obligations of the Subsidiary as its own and, on an aggregate basis with the Subsidiary, complies with the requirements of Section 18 of the 1940 Act regarding capital structure and leverage.
April 5, 2024
Page 3
Comment 8. Please disclose that any adviser to the subsidiary complies with provisions to Section 15 of the Act regarding advisory agreements and any advisory agreement with the subsidiary is added as an exhibit to the Registration Statement.
Response. The following disclosure has been added:
Any advisory or subadvisory agreement with respect to the Subsidiary meets the requirements for advisory agreements under Section 15 of the 1940 Act.
Comment 9. Please disclose that the Subsidiary complies with the affiliated transaction and custody provisions under Section 17 of the Act.
Response. The following disclosure has been added:
The Subsidiary complies with the affiliated transaction and custody provisions under Section 17 of the 1940 Act.
Comment 10. Please confirm that the subsidiary and its board of directors will agree to inspection of books and records under Section 31 of the Act.
Response. The Registrant so confirms.
Comment 11. Please include any management fees, including any performance fees, for the subsidiary in the Management Fee in the fee table and include other subsidiary expenses under Other Expenses in the fee table.
Response. The Registrant notes that such fees, if incurred, are appropriately provided for in the Fund’s fee table.
Comment 12. Please disclose that the Fund does no intent to create or invest to gain primary control in an entity primarily engaged in investment activities other than its wholly-owned subsidiary.
Response. The following disclosure has been added:
The Fund does not intent to create or invest to gain primary control in an entity primarily engaged in investment activities other than the Subsidiary.
Comment 13: Please clarify what is meant by the reference to “traditional investment process” in the Adviser’s Investment Process disclosure.
April 5, 2024
Page 4
Response: The disclosure has been revised as follows:
The Adviser replaces a sub-adviser when its returns are below expectations or it deviates from its traditional investment process with respect to changes in investment strategy.
Comment 14: With respect to the disclosure for Graham Capital Management and R.G. Niederhoffer Capital Management, please clarify what is meant “absolute returns and “stable absolute returns,” respectively.
Response: The following disclosure has been added:
“(that is, a strategy which seeks to produce positive returns over time regardless of market movements.)”
Comment 15: Please present the most important principal investment risks first and after the most important risks have been disclosed the Fund may revert back to alphabetical order.
Response: The Registrant respectfully declines to make the requested revision.
Comment 16: With respect to Derivatives Risk, please consider revising to provide more details regarding the risks of specific derivatives used by the Fund.
Response: The disclosure has been revised as follows:
• Derivatives Risk: Futures, options and swaps involve risks different from, or possibly greater than, the risks associated with investing directly in securities and other traditional investments. These risks include (i) the risk that the counterparty to a derivative transaction may not fulfill its contractual obligations; (ii) risk of mispricing or improper valuation; and (iii) the risk that changes in the value of the derivative may not correlate perfectly with the underlying asset, rate or index. The use of derivatives subject to regulation by the Commodity Futures Trading Commission (“CFTC”) by Underlying Funds may be subject to certain rules of the CFTC. Derivative prices are highly volatile and may fluctuate substantially during a short period of time. Such prices are influenced by numerous factors that affect the markets, including, but not limited to: changing supply and demand relationships; government programs and policies; national and international political and economic events, changes in interest rates, inflation and deflation and changes in supply and demand relationships.
•Futures and Forwards Risk. The primary risks associated with the use of forward and futures contracts, which may adversely affect the Fund’s net asset value (“NAV”)
April 5, 2024
Page 5
and total return, are (a) the imperfect correlation between the change in market value of the instruments held by the Fund or an Underlying Fund and the price of the forward or futures contract; (b) possible lack of a liquid secondary market for a forward or futures contract and the resulting inability to close a forward or futures contract when desired; (c) losses caused by unanticipated market movements, which are potentially unlimited; (d) the inability to predict correctly the direction of securities prices, interest rates, currency exchange rates and other economic factors; (e) the possibility that the counterparty will default in the performance of its obligations; and (f) if the Fund or Underlying Fund has insufficient cash, it may have to sell securities from its portfolio to meet daily variation margin requirements, and the Fund or Underlying Fund may have to sell securities at a time when it may be disadvantageous to do so.
•Options Risk. There are risks associated with the sale and purchase of call and put options. As the buyer of a put or call option, the Fund risks losing the entire premium invested in the option if the Fund does not exercise the option. Because option premiums paid by the Fund indirectly through Underlying Funds are small in relation to the market value of the investments underlying the options, buying and selling put and call options can be more speculative than investing directly in securities. Purchased put options may decline in value due to changes in value of the underlying reference asset.
•Swap Risk. Swap agreements are subject to the risk that the counterparty to the swap will default on its obligation to pay the Fund and the risk that the Fund will not be able to meet its obligations to pay the counterparty to the swap. In addition, there is the risk that a swap may be terminated by the Fund or the counterparty in accordance with its terms. If a swap were to terminate, the Fund may be unable to implement its investment strategies and the Fund may not be able to seek to achieve its investment objective.
Comment 17: If investing in emerging markets, please define emerging markets and disclose how investing and risks are different than foreign risks.
Response: The following disclosure has been added:
Through its Managed Futures and Commodities strategies, the Fund will have exposure to underlying assets in the U.S. as well as foreign and emerging markets. The Fund defines emerging markets as those that are found in the MSCI Emerging Markets Index.
Comment 18: Please clarify if frequent trading is a principal investment strategy, and if so, please disclose in the principal investment strategy section.
April 5, 2024
Page 6
Response: The Registrant does not believe frequent trading will be a principal investment strategy for the Fund.
Comment 19: Please reconcile any differences in the Managed Futures strategy disclosure in Items 4 and 10.
Response: The disclosure in Item 10 has been revised as follows:
The Managed Futures strategy is designed to produce capital appreciation by capturing returns related to the commodity and financial markets by investing long or short in: (i) futures, (ii) forwards, (iii) options, (iv) spot contracts, or (v) swaps, each of which may be tied to (a) currencies including Bitcoin and Ethereum cryptocurrencies, (b) interest rates, (c) stock market indices, (d) energy resources, (e) metals or (f) agricultural products.
Comment 20: Please define “Index” as described in the disclosure for the Commodities Futures strategy.
Response: The disclosure has been revised as follows:
To the extent the Adviser is utilizing derivatives to gain exposure to managers, it is anticipated that the Fund uses a total return swap (the "Swap"), a type of derivative instrument based on a customized index (the "Index") designed to replicate the aggregate returns of the managers selected by the Adviser.
Comment 21: With respect to the description of the investment process for R.G. Niederhoffer, please clarify what is meant by “behavioral biases.”
Response: The Registrant respectfully declines to revise the existing disclosure.
Comment 22: Please include LIBOR transition risk, if applicable, and how the successor reference rate may impact the value of such securities.
Response: The Fund’s adviser confirms that LIBOR risk is not a principal risk of the Fund.
Comment 23: Please revise references to “Funds” in the Credit Risk and Wholly-Owned Subsidiary Risk disclosures and correct the typo “Funs” in Market Risk.
Response: The requested revisions have been made.
Comment 24: Please delete the duplicative Covid-19 sentence in Market Risk.
April 5, 2024
Page 7
Response: The requested revisions has been made.
Comment 25: Please include Preferred Stock Risk in the summary section or delete if not applicable.
Response: The risk has been deleted.
Comment 26: Please add “Section” prior to the reference to 1256 futures contracts.
Response: The requested revision has been made.
Comment 27: Please add a reference to the Fund’s website in the Portfolio Holdings Disclosure section.
Response: The requested revision has been made.
Comment 28: Please complete the assets under management disclosures for the subadvisers.
Response: The requested revisions has been made.
Comment 29: Please consider the Foreign Risk disclosure to disclose risks associated with the value of Underlying Funds that hold foreign securities.
Response: The Registrant respectfully declines to amend the existing disclosure and notes that Underlying Funds with foreign holdings are not a principal investment strategy for the Fund.
Comment 30: Please add the date of the commencement of the Fund’s operations in the Financial Highlights disclosure.
Response: The disclosure has been revised as follows:
The Fund only recently commenced operations in May 2024.
Comment 31: Please revise the reference to registered representatives and complete the omitted disclosures in the Baird sales charge waiver section.
Response: The requested revisions have been made.
Comment 32: Please define “OPCO” in the Oppenheimer and Co Inc. sales charge waiver disclosure.
Response: The requested revisions have been made.
April 5, 2024
Page 8
SAI
Comment 33: Please provide additional disclosure for parent companies of Graham Capital Management and Nuveen Asset Management.
Response: The following disclosure has been added:
Graham: The general partner of GCM is KGT, Inc., a Delaware corporation of which Kenneth G. Tropin (the firm’s Chairman and Founder) is the President and ultimate sole shareholder. The limited partner of GCM is KGT Investment Partners L.P., a Delaware limited partnership of which KGT, Inc. is also a general partner and in which Mr. Tropin and members of his immediate family are significant beneficial owners. Dyal Capital, formerly a Neuberger Berman company and, as of 2021, a division of Blue Owl Capital Inc., owns an indirect minority interest in the firm.
Nuveen: Nuveen, LLC is a subsidiary and the investment manager of Teachers Insurance and Annuity Association of America (TIAA), a leading financial services provider serving over 5 million individual participants and 15,000 institutions worldwide as of March 31, 2023.
Comment 34: Please provide the Fund’s website in the Proxy Voting Policies disclosure.
Response: The requested additional disclosure has been provided.
Comment 35: Please provide the Other Accounts information for the portfolio managers as of a recent date.
Response: Information as of March 31, 2024 will be provided in the post-effective amendment.
Comment 36: Please provide the subsidiary’s name and delete references to Subsidiaries, unless applicable.
Response: The requested revisions have been made. Supplementally, the Subsidiary is named LCHC Fund Limited.
Comment 37: Please disclose that the Fund