SEC Company Response from Angel Oak Financial Strategies Income Term Trust (FINS) (CIK 0001745059) (FINS) — May 25, 2022
Angel Oak Financial Strategies Income Term Trust (FINS) (CIK 0001745059)
Date: May 25, 2022 · CIK: 0001745059 · Accession: 0001193125-22-159348
AI Filing Summary & Sentiment
File numbers found in text: 333-264318
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CORRESP
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Angel Oak Financial Strategies Income Term Trust
1900 K Street, NW
Washington, DC 20006
+1 202 261 3300 Main
+1 202 261 3333 Fax
www.dechert.com
May 25, 2022
VIA EDGAR
U.S. Securities and Exchange Commission
Division of
Investment Management
100 F Street, NE
Washington, DC 20549
Attn: Emily Rowland
Re:
Angel Oak Financial Strategies Income Term Trust (the “Fund”) (File
No. 333-264318) – Information Statement/Prospectus Filing
Dear Ms. Rowland:
This letter responds to comments you conveyed via telephone on May 24, 2022, to me in connection with the Securities and Exchange Commission
(“SEC”) staff’s review of the preliminary information statement and prospectus and related materials on Form N-14 (the “Information Statement/Prospectus”) that was filed by the Fund on
April 15, 2022, and the responses to the SEC staff’s comments received on May 10, 2022, and May 23, 2022. Capitalized terms not defined herein have the definitions provided to them in the Information Statement/Prospectus.
1.
Comment: Please disclose that none of the waived fees and expenses of the Acquired Fund are
subject to recoupment by the Adviser after the Reorganization.
Response: Although the Adviser believes it
has the ability to recoup previously waived fees and expenses of the Acquired Fund under the terms of the Expense Limitation Agreement and Agreement and Plan of Reorganization, the Fund has added the following:
The Adviser will not recoup the waived fees and expenses of the Acquired Fund after the Reorganization.
2.
Comment: Please supplementally confirm that the Acquiring Fund has no previously waived fees and
expenses subject to recoupment.
Response: The Fund confirms that the Acquiring Fund has no previously
waived fees and expenses subject to recoupment.
3.
Comment: Please disclose that the Acquiring Fund has no current intention to issue preferred
shares in the 12 months following the Reorganization.
Response: The Fund has added the following:
As of the date of this Information Statement/Prospectus, the Acquiring Fund does not currently intend to issue preferred shares in the 12
months following the Reorganization.
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Should you have any questions or comments, please contact me at 202.261.3304.
Sincerely,
/s/ Stephen T. Cohen
Stephen T. Cohen