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SEC Company Response from ROYCE GLOBAL VALUE TRUST, INC. (RGT) (CIK 0001514490) (RGT) — May 14, 2020

ROYCE GLOBAL VALUE TRUST, INC. (RGT) (CIK 0001514490)
Date: May 14, 2020 · CIK: 0001514490 · Accession: 0000949377-20-000143

AI Filing Summary & Sentiment

File numbers found in text: 811-04875, 811-08030, 811-22532

Date
May 14, 2020
Author
Secretary
Form
CORRESP
Company
ROYCE GLOBAL VALUE TRUST, INC. (RGT) (CIK 0001514490)

Letter

VIA EDGAR CORRESPONDENCE Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Atten: Ms. Cindy Chang Re: Annual Report to Stockholders for the year ended December 31, 2019 for each of Royce Micro-Cap Trust, Inc. (File No. 811-08030), Royce Value Trust, Inc. (File No. 811-04875), and Royce Global Value Trust, Inc. (File No. 811-22532)

Dear Ms. Chang:

At your request, and as we discussed over the telephone, in connection with the staff’s comments relating to each of the above-referenced Annual Reports to Stockholders, set forth below are the staff’s comments and the Funds’ responses.

Royce Micro-Cap Trust, Inc. Royce Value Trust, Inc.

Royce Global Value Trust, Inc,

Comment: Please amend each Funds’ Form N-CEN to attach each Funds’ internal control report from the Funds’ Independent Accountants for the year ended December 31, 2019.

Response: On April 17, 2020, each Fund filed a Form N-CEN/A for the year ended December 31, 2019 per your above request.

Comment: Please include disclosure in the Notes to the Financial Statements contained in the Funds’ Annual Reports to Stockholders that sets forth disclosure regarding the maximum amount of borrowing permitted under each Funds’ revolving credit agreement and the conditions under which such line of credit may be withdrawn from each Fund (See Reg-SX 210.5-02.19b).

Response: We will expand the disclosure regarding borrowings per the above request in future N-CSR filings.

Please direct any further communication relating to this filing to John E. Denneen at (212) 508-4578.

Very
truly yours,
/s/ Peter K. Hoglund
/s/ John E. Denneen

Show Raw Text
CORRESP
1
filename1.htm

The
Royce Funds

745 Fifth Avenue

New
York, NY 10151

212-508-4500

800-221-4268

e-mail:
funds@royceinvest.com website: www.royceinvest.com

May 14, 2020

VIA
EDGAR CORRESPONDENCE

Securities
and Exchange Commission

Division of Investment
Management

100 F Street,
N.E. Washington, D.C. 20549

Atten: Ms. Cindy Chang

Re:
Annual Report to Stockholders for the year
ended December 31, 2019 for each of Royce
Micro-Cap Trust, Inc. (File No. 811-08030),
Royce Value Trust, Inc.

(File No. 811-04875),
and Royce Global Value Trust, Inc. (File
No. 811-22532)

Dear
Ms. Chang:

At
your request, and
as we discussed over the telephone,
in connection with the staff’s comments
relating to each of the above-referenced
Annual Reports to Stockholders,
set forth below are the staff’s comments and
the Funds’ responses.

Royce Micro-Cap Trust, Inc.
Royce Value Trust, Inc.

Royce Global Value Trust, Inc,

Comment:
Please amend each
Funds’ Form N-CEN to attach
each Funds’ internal control report
from the Funds’ Independent Accountants
for the year ended December 31, 2019.

Response:
On April 17, 2020, each
Fund filed a Form
N-CEN/A for the
year ended December 31,
2019 per your
above request.

Comment:
Please include disclosure in the Notes
to the Financial Statements contained
in the Funds’ Annual Reports to
Stockholders that sets forth
disclosure regarding the maximum
amount of borrowing permitted under
each Funds’ revolving credit agreement and the
conditions under which
such line of credit may be
withdrawn from each Fund (See Reg-SX 210.5-02.19b).

Response:
We will expand the disclosure regarding borrowings
per the above request in future N-CSR
filings.

Please
direct any further communication relating
to this filing to John E. Denneen at (212)
508-4578.

Very
truly yours,

    /s/ Peter K. Hoglund
    /s/ John E. Denneen

    Peter K. Hoglund
    John E. Denneen

    Treasurer
    Secretary

    cc:
    Christopher D. Clark
Mary Macchia

Frank P. Bruno, Esq.