Correspondence 0001104659-23-088173 from CION Ares Diversified Credit Fund (CADCX) (CIK 0001678124)
CION Ares Diversified Credit Fund (CADCX) (CIK 0001678124)
Date: Aug. 7, 2023 · CIK: 0001678124 · Accession: 0001104659-23-088173
AI Filing Summary & Sentiment
File numbers found in text: 333-271529
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Mr. Jeffrey Long Re: CION Ares Diversified Credit Fund, File No. 333-271529 (the “Fund”)
Dear Mr. Long:
We are writing in response to your comments with respect to your review, pursuant to the Sarbanes-Oxley Act of 2002, of the annual report of the Fund filed on Form N-CSR relating to the fiscal year ended December 31, 2022 (the “Annual Report”). The Fund has considered your comments and has authorized us, on its behalf, to make the responses discussed below.
On behalf of the Fund, set forth below are the comments from the Staff of the Securities and Exchange Commission, along with our responses to such comments, as requested. All capitalized terms not defined herein shall have the meaning as set forth in the Annual Report.
Annual Report
1. Comment: Footnote (d) in the Schedule of Investments states that certain investments, which represented 135.65% of the Fund’s net assets, may be subject to legal restrictions on sales. Please confirm that the Fund has included disclosure as required by Rule 12-12 of Regulation S-X relating to restricted securities, if applicable.
Response: The Fund confirms that the referenced investments do not require disclosure per Rule 12-12 of Regulation S-X. The Fund will include such disclosure in the Fund’s future filings, if applicable.
2. Comment: To the extent the Fund receives fees such as consent fees, upfront origination fees or amendment fee income in an amount that exceeds 5% of the Fund’s total income, please disclose such amounts separately.
Response: The disclosure will be revised as requested in the Fund’s future filings, if applicable.
* * * * *
Should you have any questions or comments, please contact the undersigned at 212.641.5600.
Sincerely,
/s/ Jonathan Gaines
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CORRESP
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filename1.htm
1095 Avenue of the Americas
New York, NY 10036-6797
+1 212 698 3500 Main
+1 212 698 3599 Fax
www.dechert.com
Jonathan Gaines
jonathan.gaines@dechert.com
+1 212 641 5600 Direct
+1 212 698 3599 Fax
August 7, 2023
VIA EDGAR
Division of Investment Management
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Attn: Mr. Jeffrey Long
Re: CION Ares Diversified Credit Fund, File No. 333-271529 (the “Fund”)
Dear Mr. Long:
We are writing in response to your comments with
respect to your review, pursuant to the Sarbanes-Oxley Act of 2002, of the annual report of the Fund filed on Form N-CSR relating to the
fiscal year ended December 31, 2022 (the “Annual Report”). The Fund has considered your comments and has authorized us, on
its behalf, to make the responses discussed below.
On behalf of the Fund, set forth below are the
comments from the Staff of the Securities and Exchange Commission, along with our responses to such comments, as requested. All capitalized
terms not defined herein shall have the meaning as set forth in the Annual Report.
Annual Report
1. Comment: Footnote (d) in the Schedule of Investments states that certain investments, which
represented 135.65% of the Fund’s net assets, may be subject to legal restrictions on sales. Please confirm that the Fund has included
disclosure as required by Rule 12-12 of Regulation S-X relating to restricted securities, if applicable.
Response: The
Fund confirms that the referenced investments do not require disclosure per Rule 12-12 of Regulation S-X. The Fund will include such disclosure
in the Fund’s future filings, if applicable.
2. Comment: To the extent the Fund receives fees such as consent fees, upfront origination fees
or amendment fee income in an amount that exceeds 5% of the Fund’s total income, please disclose such amounts separately.
Response: The
disclosure will be revised as requested in the Fund’s future filings, if applicable.
* * * * *
Should you have any questions or comments, please contact the undersigned
at 212.641.5600.
Sincerely,
/s/ Jonathan Gaines
Jonathan Gaines
2