Correspondence 0001072613-23-000625 from BARINGS GLOBAL SHORT DURATION HIGH YIELD FUND (BGH)
BARINGS GLOBAL SHORT DURATION HIGH YIELD FUND
Date: Dec. 15, 2023 · CIK: 0001521404 · Accession: 0001072613-23-000625
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 811-22562
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission F Street, N.E. Washington, D.C. 20549-0504 Re: Barings Global Short Duration High Yield Fund (File No. 811-22562) (the “Fund”) – Review of Annual Report Disclosure
Dear Ms. Hamilton:
We are writing in response to comments provided by the Staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission on October 26, 2023 with respect to the Fund’s Annual Report on Form N-CSR for the year ended December 31, 2022, filed on March 10, 2023 (the “Report”). The Fund has considered your comments and has authorized us, on its behalf, to make the responses discussed below. All terms not defined herein shall have the meaning ascribed in the Report.
On behalf of the Fund, set forth below are the Staff’s comments along with our responses to or any supplemental explanations of such comments, as requested.
1. Comment: The Staff notes that Item 4(d) of the certification pursuant to Rule 30a-2(a) under the Investment Company Act of 1940, as amended (“1940 Act”) and Section 302 of the Sarbanes-Oxley Act of 2002, as amended, attached to the Report (the “Certification”) refers to the “fourth quarter of the period” covered by the Report. Please file an amended Report with a revised Certification that includes the language provided in Form N-CSR Item 13(a)(2) which refers to the period covered by the report.
Response: The Fund respectfully acknowledges the Staff’s comment and will file an amended Report with a revised Certification.
2. Comment: The Staff notes that Item 11(b) of the Report refers to a specified time period (i.e., “second half year”) but Item 11(b) of Form N-CSR requires the period covered by the report (i.e., full year). Please supplementally confirm (i) that the required period will be included an amended Form N-CSR filing and (ii) that there were no changes to the Fund’s internal controls over financial reporting during the period covered by the report that have materially affected, or are reasonably likely to materially affect, the Fund’s internal control over financial reporting.
Response: The Fund respectfully acknowledges the Staff’s comment and (i) will incorporate the relevant disclosure in an amended Form N-CSR filing and (ii) confirms that there were no changes to the Fund’s internal controls on financial reporting during the period covered by the report that have materially affected, or are reasonably likely to materially affect, the Fund’s internal control over financial reporting.
3. Comment: Please supplementally explain how the Report satisfies the disclosure requirements of Rule 8b-16(b)(4) of the 1940 Act.
Response: The Fund respectfully acknowledges the Staff’s comment and will include disclosure that is responsive to Rule 8b-16(b)(4) of the 1940 Act in an amended Form N-CSR filing.
4. Comment: The Staff notes that the third footnote on page 21 to the Schedule of Investments refers to “June 30, 2022.” Please (i) supplementally clarify whether this is the correct date and (ii) ensure that the correct date is provided in future filings.
Response: The Fund respectfully acknowledges the Staff’s comment and confirms (i) this date will be revised in the amended Form N-CSR filing to “December 31, 2022” and (ii) will incorporate the relevant disclosure in future filings accordingly.
5. Comment: The Staff notes that, in response to Item C.9.e. of the Fund’s filings on Form N-PORT, the Fund has disclosed that certain of its holdings receive a portion of interest in-kind. The Staff notes that the Report does not include corresponding disclosure on in-kind interest payments. Please supplementally clarify this discrepancy and revise, as appropriate, in an amended Form N-CSR filing.
Response: The Fund respectfully acknowledges the Staff’s comment and supplementally clarifies that two of the Fund’s holdings received interest in-kind during the year ended December 31, 2022. The Fund will incorporate the relevant disclosure in an amended Form N-CSR filing and will undertake to file an amended Form N-PORT.
* * * * *
Please do not hesitate to contact the undersigned at (212) 698-3525 with any questions or comments concerning this correspondence.
Sincerely,
/s/
Richard Horowitz
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CORRESP
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filename1.htm
Three Bryant
Park
1095 Avenue of the Americas
New York, NY 10036-6797
+1 212 698 3500
Main
+1 212 698 3599
Fax
www.dechert.com
Richard
Horowitz
Richard.Horowitz@dechert.com
+1
212 698 3525 Direct
+1
212 698 0452 Fax
December
15, 2023
VIA
EDGAR
Lauren
Hamilton
Division
of Investment Management
Securities
and Exchange Commission
100
F Street, N.E.
Washington,
D.C. 20549-0504
Re: Barings
Global Short Duration High Yield Fund (File No. 811-22562) (the “Fund”) –
Review of Annual Report Disclosure
Dear
Ms. Hamilton:
We
are writing in response to comments provided by the Staff of the Division of Investment Management (the “Staff”) of the Securities
and Exchange Commission on October 26, 2023 with respect to the Fund’s Annual Report on Form N-CSR for the year ended December
31, 2022, filed on March 10, 2023 (the “Report”). The Fund has considered your comments and has authorized us, on its behalf,
to make the responses discussed below. All terms not defined herein shall have the meaning ascribed in the Report.
On
behalf of the Fund, set forth below are the Staff’s comments along with our responses to or any supplemental explanations of such
comments, as requested.
1. Comment: The
Staff notes that Item 4(d) of the certification pursuant to Rule 30a-2(a) under the Investment
Company Act of 1940, as amended (“1940 Act”) and Section 302 of the Sarbanes-Oxley
Act of 2002, as amended, attached to the Report (the “Certification”) refers
to the “fourth quarter of the period” covered by the Report. Please file an amended
Report with a revised Certification that includes the language provided in Form N-CSR Item
13(a)(2) which refers to the period covered by the report.
Response: The
Fund respectfully acknowledges the Staff’s comment and will file an amended Report with a revised Certification.
2. Comment: The
Staff notes that Item 11(b) of the Report refers to a specified time period (i.e.,
“second half year”) but Item 11(b) of Form N-CSR requires the period covered
by the report (i.e., full year). Please supplementally confirm (i) that the required
period will be included an amended Form N-CSR filing and (ii) that there were no changes
to the Fund’s internal controls over financial reporting during the period covered
by the report that have materially affected, or are reasonably likely to materially affect,
the Fund’s internal control over financial reporting.
Response: The
Fund respectfully acknowledges the Staff’s comment and (i) will incorporate the relevant disclosure in an amended Form N-CSR filing
and (ii) confirms that there were no changes to the Fund’s internal controls on financial reporting during the period covered by
the report that have materially affected, or are reasonably likely to materially affect, the Fund’s internal control over financial
reporting.
3. Comment: Please
supplementally explain how the Report satisfies the disclosure requirements of Rule 8b-16(b)(4)
of the 1940 Act.
Response: The
Fund respectfully acknowledges the Staff’s comment and will include disclosure that is responsive to Rule 8b-16(b)(4) of the 1940
Act in an amended Form N-CSR filing.
4. Comment: The
Staff notes that the third footnote on page 21 to the Schedule of Investments refers to “June
30, 2022.” Please (i) supplementally clarify whether this is the correct date and (ii)
ensure that the correct date is provided in future filings.
Response: The
Fund respectfully acknowledges the Staff’s comment and confirms (i) this date will be revised in the amended Form N-CSR filing
to “December 31, 2022” and (ii) will incorporate the relevant disclosure in future filings accordingly.
2
5. Comment: The
Staff notes that, in response to Item C.9.e. of the Fund’s filings on Form N-PORT,
the Fund has disclosed that certain of its holdings receive a portion of interest in-kind.
The Staff notes that the Report does not include corresponding disclosure on in-kind interest
payments. Please supplementally clarify this discrepancy and revise, as appropriate, in an
amended Form N-CSR filing.
Response: The
Fund respectfully acknowledges the Staff’s comment and supplementally clarifies that two of the Fund’s holdings received
interest in-kind during the year ended December 31, 2022. The Fund will incorporate the relevant disclosure in an amended Form N-CSR
filing and will undertake to file an amended Form N-PORT.
*
* * * *
Please
do not hesitate to contact the undersigned at (212) 698-3525 with any questions or comments
concerning this correspondence.
Sincerely,
/s/
Richard Horowitz
Richard
Horowitz
3