Correspondence 0001104659-22-123794 from FIRST TRUST ALTERNATIVE OPPORTUNITIES FUND (VFLEX) (CIK 0001681717)
FIRST TRUST ALTERNATIVE OPPORTUNITIES FUND (VFLEX) (CIK 0001681717)
Date: Dec. 1, 2022 · CIK: 0001681717 · Accession: 0001104659-22-123794
AI Filing Summary & Sentiment
File numbers found in text: 333-213003, 811-23179
Letter
VIA EDGAR TRANSMISSION Washington, D.C. 20549 Attention: David Orlich Re: First Trust Alternative Opportunities Fund (the “Fund” or the “Registrant”) (File Nos. 333-213003; 811-23179); Response to Examiner Comments on PRE 14A
Dear Mr. Orlich:
This letter responds to the staff’s comment that you provided via telephone on November 22, 2022, in connection with your review of the Fund’s above-referenced preliminary proxy statement (“Proxy Statement”) on Schedule 14A. The changes to the Fund’s disclosure discussed below will be reflected in the Fund’s definitive Proxy Statement.
For your convenience, we have repeated your comment below in bold, and our response follows your comment. Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Proxy Statement, unless otherwise indicated.
1. Please confirm all applicable information required by Item 22(c) of Schedule 14A has been disclosed, including Item 22(c)(2) (in particular information about directors or general partners of Palmer Square).
With respect to Item 22(c)(2) of Schedule 14A, the Registrant has revised the disclosure in the Proxy Statement under the heading “Information About Palmer Square Capital Management, LLC” as follows:
Palmer Square Capital Management LLC is located at 1900 Shawnee Mission Parkway, Suite 315, Mission Woods, KS 66205, which is the address of the following individuals who constitute the principal executive officers of Palmer Square. Christopher D. Long, Founder, CEO, President and Chairman of Palmer Square and Angie K. Long, Chief Investment Officer of Palmer Square have a controlling interest in Palmer Square as members of Palmer Square, which is a limited liability company. Each of Mr. Long’s and Ms. Long’s principal occupation is their respective position at Palmer Square. As of May 31, 2022, Palmer Square has $22.4 billion in assets under management.
The Registrant supplementally confirms that all other applicable information required by Item 22(c) of Schedule 14A has been disclosed.
We trust that the foregoing is responsive to your comments. Questions and comments concerning this filing may be directed to the undersigned at (312) 569-1167.
Sincerely,
/s/ Veena K. Jain
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CORRESP
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Faegre Drinker Biddle & Reath LLP
320 South Canal Street, Suite 3300
Chicago, IL 60606
(312) 569-1000 (Phone)
(312) 569-3000 (Facsimile)
www.faegredrinker.com
December 1, 2022
VIA EDGAR TRANSMISSION
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: David Orlich
Re: First Trust Alternative Opportunities
Fund (the “Fund” or the “Registrant”)
(File Nos. 333-213003; 811-23179); Response to Examiner Comments on PRE 14A
Dear Mr. Orlich:
This letter responds to the
staff’s comment that you provided via telephone on November 22, 2022, in connection with your review of the Fund’s above-referenced
preliminary proxy statement (“Proxy Statement”) on Schedule 14A. The changes to the Fund’s disclosure discussed below
will be reflected in the Fund’s definitive Proxy Statement.
For your convenience, we have
repeated your comment below in bold, and our response follows your comment. Capitalized terms not otherwise defined herein shall have
the meaning ascribed to them in the Proxy Statement, unless otherwise indicated.
1. Please confirm all applicable information required by Item 22(c) of Schedule 14A has been disclosed,
including Item 22(c)(2) (in particular information about directors or general partners of Palmer Square).
With respect to Item 22(c)(2) of
Schedule 14A, the Registrant has revised the disclosure in the Proxy Statement under the heading “Information About Palmer Square
Capital Management, LLC” as follows:
Palmer
Square Capital Management LLC is located at 1900 Shawnee Mission Parkway, Suite 315, Mission Woods, KS 66205, which is the address
of the following individuals who constitute the principal executive officers of Palmer Square. Christopher D. Long, Founder, CEO, President
and Chairman of Palmer Square and Angie K. Long, Chief Investment Officer of Palmer Square have a controlling interest in Palmer Square
as members of Palmer Square, which is a limited liability company. Each of Mr. Long’s and Ms. Long’s
principal occupation is their respective position at Palmer Square. As of May 31, 2022, Palmer Square has $22.4 billion in
assets under management.
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The Registrant supplementally confirms
that all other applicable information required by Item 22(c) of Schedule 14A has been disclosed.
We trust that
the foregoing is responsive to your comments. Questions and comments concerning this filing may be directed to the undersigned at (312)
569-1167.
Sincerely,
/s/ Veena K. Jain
Veena K. Jain
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