Correspondence 0001213900-23-043444 from ALTI PRIVATE EQUITY ACCESS & COMMITMENTS FUND (CIK 0001759455)
ALTI PRIVATE EQUITY ACCESS & COMMITMENTS FUND (CIK 0001759455)
Date: May 26, 2023 · CIK: 0001759455 · Accession: 0001213900-23-043444
AI Filing Summary & Sentiment
File numbers found in text: 333-235545, 811-23501
Letter
VIA EDGAR AND OVERNIGHT MAIL Division of Investment Management 100 F Street, N.E. Washington, DC 20549 Re: ALTI Private Equity Access & Commitments Fund (the “Fund”) Registration Statement on Form N-2 File Nos. 333-235545, 811-23501
Dear Mr. Sutcliffe:
This letter is in response to oral comments received from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) on January 6, 2023 regarding a Registration Statement on Form N-2 (the “Registration Statement”) relating to the ALTI Private Equity Access Fund (the “Fund”).
The following sets forth the Staff’s comments and the Fund’s responses thereto.
1. Please delete duplicative “Total Annual Expenses” line item on page 15 of prospectus. Please remove footnote 4 in the Fee Table on page 15 of prospectus.
The Fund has updated the Registration Statement as requested.
2. Please reconcile the description of the termination provision of the Expense Limitation Agreement as set forth in the prospectus with the same as set forth in the actual Agreement.
The Fund has updated the Registration Statement as requested.
3. Please delete the parenthetical “(the example assumes the Fund’s Expense Limitation Agreement will remain in effect for only one year, which is the length of the contracted Expense Limitation Agreement)” at the top of page 16 of prospectus.
The Fund has updated the Registration Statement as requested.
4. Please insert the organizational meeting date on page 29 of the SAI.
The Fund has updated the Registration Statement as requested.
5. Please address the brackets on page 29 of the SAI.
The Fund has updated the Registration Statement as requested.
6. Please change “his” to “her” on page 30 of the SAI (Schwartz’s bio).
The Fund has updated the Registration Statement as requested.
7. Please file remaining exhibits in next amendment.
The Fund has updated the Registration Statement as requested.
8. Please file the Expense Limitation Agreement as a material contract.
The Fund has updated the Registration Statement as requested.
9. With respect to the signature page, please ensure all aspects of Section 6A of the Securities Act are fulfilled.
The Fund has updated the Registration Statement as requested.
10. The Fund as it is presented has capital commitments that may be in cash for indefinite periods of time and therefore does not appear to be in compliant with the term private equity with respect to the names rule. Please revise the strategy or the name.
The Fund has updated the Registration Statement as requested. The Fund name has been changed to Alti Private Equity Access and Commitments Fund.
Should you have any questions regarding this letter, please contact me at (212) 506-2275.
Sincerely,
Anna T. Pinedo, Esq.
Show Raw Text
CORRESP
1
filename1.htm
ALTI Private Equity Access & Commitments Fund
May 26, 2023
VIA EDGAR AND OVERNIGHT MAIL
Ryan Sutcliffe, Esquire
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: ALTI Private Equity Access & Commitments Fund (the “Fund”)
Registration Statement on Form N-2 File Nos.
333-235545, 811-23501
Dear Mr. Sutcliffe:
This letter is in response to oral comments received
from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) on January 6,
2023 regarding a Registration Statement on Form N-2 (the “Registration Statement”) relating to the ALTI Private Equity
Access Fund (the “Fund”).
The following sets forth the Staff’s comments
and the Fund’s responses thereto.
1. Please delete duplicative “Total Annual Expenses” line item on page 15 of prospectus.
Please remove footnote 4 in the Fee Table on page 15 of prospectus.
The
Fund has updated the Registration Statement as requested.
2. Please reconcile the description of the termination provision of the Expense Limitation Agreement
as set forth in the prospectus with the same as set forth in the actual Agreement.
The
Fund has updated the Registration Statement as requested.
3. Please delete the parenthetical “(the example assumes the Fund’s Expense Limitation
Agreement will remain in effect for only one year, which is the length of the contracted Expense Limitation Agreement)” at the top
of page 16 of prospectus.
The
Fund has updated the Registration Statement as requested.
4. Please insert the organizational meeting date on page 29 of the SAI.
The
Fund has updated the Registration Statement as requested.
1
5. Please address the brackets on page 29 of the SAI.
The
Fund has updated the Registration Statement as requested.
6. Please change “his” to “her” on page 30 of the SAI (Schwartz’s bio).
The
Fund has updated the Registration Statement as requested.
7. Please file remaining exhibits in next amendment.
The
Fund has updated the Registration Statement as requested.
8. Please file the Expense Limitation Agreement as a material contract.
The
Fund has updated the Registration Statement as requested.
9. With respect to the signature page, please ensure all aspects of Section 6A of the Securities Act
are fulfilled.
The
Fund has updated the Registration Statement as requested.
10. The Fund as it is presented has capital commitments that may be in cash for indefinite periods of
time and therefore does not appear to be in compliant with the term private equity with respect to the names rule. Please revise
the strategy or the name.
The
Fund has updated the Registration Statement as requested. The Fund name has been changed to Alti Private Equity Access and Commitments
Fund.
Should you have any questions regarding this letter,
please contact me at (212) 506-2275.
Sincerely,
Anna T. Pinedo, Esq.
Cc: Joseph Bonvouloir
2