Correspondence 0001398344-24-018173 from RiverNorth Opportunistic Municipal Income Fund, Inc. (RMI)
RiverNorth Opportunistic Municipal Income Fund, Inc.
Date: Sept. 25, 2024 · CIK: 0001746967 · Accession: 0001398344-24-018173
AI Filing Summary & Sentiment
File numbers found in text: 333-281401, 811-233666
Letter
VIA EDGAR TRANSMISSION Washington, D.C. 20549 Attention: Megan F. Miller Re: RiverNorth Opportunistic Municipal Income Fund, Inc. (the “Fund”) (File Nos. 333-281401; 811-233666)
Dear Ms. Miller:
The following responds to the comments of the staff of the Securities and Exchange Commission (“Staff”) that you provided by telephone on August 19, 2024, relating to the Fund’s June 30, 2023 annual report filed with the Securities and Exchange Commission on Form N-CSR on November 20, 2023 (the “Annual Report”).
For your convenience, the Staff’s comments are summarized below and each comment is followed by the Registrant’s response.
1. Comment: Please explain why securities are tagged as held as collateral or a loan payable, but there is no loan payable on the balance sheet.
Response: The credit agreement requires a minimal amount of collateral to be held in order to maintain the account open, regardless if an amount is drawn on such account. Therefore, although there is no loan payable currently reflected on the balance sheet, the securities are held as collateral in compliance with the agreement. These securities held as collateral remain in the possession of the Fund’s custodian through a tri-party agreement.
2. Comment: The Staff noted that the fund has a distribution policy or practice of maintaining a specified level of distributions and paid a return of capital on a prospective basis. Please include a discussion of the extent to which the Fund’s distribution policy resulted in distributions of capital or impacted strategies or NAVs.
Response: The Registrant confirms that it will, going forward, include the requested information when applicable.
* * * * *
We trust that the foregoing is responsive to your comments. Questions and comments concerning this filing may be directed to the undersigned at 312-569-1107.
Sincerely,
/s/ David L. Williams
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Faegre Drinker Biddle & Reath LLP
320 S. Canal Street, Suite 3300
Chicago, IL 60606
(312) 569-1000 (Phone)
(312) 569-3000 (Facsimile)
www.faegredrinker.com
September 25, 2024
VIA EDGAR TRANSMISSION
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Megan F. Miller
Re: RiverNorth Opportunistic Municipal Income Fund, Inc. (the “Fund”)
(File Nos. 333-281401; 811-233666)
Dear Ms. Miller:
The following responds to the comments of the staff
of the Securities and Exchange Commission (“Staff”) that you provided by telephone on August 19, 2024, relating to the Fund’s
June 30, 2023 annual report filed with the Securities and Exchange Commission on Form N-CSR on November 20, 2023 (the “Annual Report”).
For your convenience, the Staff’s
comments are summarized below and each comment is followed by the Registrant’s response.
1. Comment: Please explain why securities are tagged as held as collateral or a loan payable, but
there is no loan payable on the balance sheet.
Response: The credit agreement requires a minimal
amount of collateral to be held in order to maintain the account open, regardless if an amount is drawn on such account. Therefore, although
there is no loan payable currently reflected on the balance sheet, the securities are held as collateral in compliance with the agreement.
These securities held as collateral remain in the possession of the Fund’s custodian through a tri-party agreement.
2. Comment: The Staff noted that the fund has a distribution policy or practice of maintaining
a specified level of distributions and paid a return of capital on a prospective basis. Please include a discussion of the extent to which
the Fund’s distribution policy resulted in distributions of capital or impacted strategies or NAVs.
Response: The Registrant confirms that it will,
going forward, include the requested information when applicable.
* * * * *
We trust that the foregoing is responsive to your comments. Questions and
comments concerning this filing may be directed to the undersigned at 312-569-1107.
Sincerely,
/s/ David L. Williams
David L. Williams