Correspondence 0001213900-23-054728 from ALTI PRIVATE EQUITY ACCESS & COMMITMENTS FUND (CIK 0001759455)
ALTI PRIVATE EQUITY ACCESS & COMMITMENTS FUND (CIK 0001759455)
Date: July 5, 2023 · CIK: 0001759455 · Accession: 0001213900-23-054728
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 and 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 June 9, 2023 regarding a Registration Statement on Form N-2 (the “Registration Statement”) relating to the ALTI Private Equity Access and Commitments Fund (the “Fund”).
The following sets forth the Staff’s comments and the Fund’s responses thereto.
1. With respect to the description of the Expense Reimbursement Agreement’s term on page 41 of the Registration Statement, please revise to reference the two year period set forth in the Agreement instead of the Limitation Period (as defined in the Expense Limitation Agreement).
The Fund has updated the Registration Statement as requested.
2. Please revise the statement “The Fund expects to initially allocate substantially all of its assets to the Sub-Adviser” to clarify the expected initial allocation to the Sub-Adviser.
The Fund has updated the Registration Statement as requested.
3. Please revise the “Use of Proceeds” to clarify the Fund’s use of net proceeds during the initial allocation period.
The Fund has updated the Registration Statement as requested.
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 and Commitments Fund
July 5, 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 and 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 June 9, 2023
regarding a Registration Statement on Form N-2 (the “Registration Statement”) relating to the ALTI Private Equity Access
and Commitments Fund (the “Fund”).
The following sets forth the Staff’s comments
and the Fund’s responses thereto.
1. With respect to the description of the Expense Reimbursement Agreement’s term on page 41 of the Registration Statement,
please revise to reference the two year period set forth in the Agreement instead of the Limitation Period (as defined in the Expense
Limitation Agreement).
The
Fund has updated the Registration Statement as requested.
2. Please revise the statement “The Fund expects to initially allocate substantially all of its assets to the Sub-Adviser”
to clarify the expected initial allocation to the Sub-Adviser.
The
Fund has updated the Registration Statement as requested.
3. Please revise the “Use of Proceeds” to clarify the Fund’s use of net proceeds during the initial allocation
period.
The
Fund has updated the Registration Statement as requested.
Should you have any questions regarding this letter,
please contact me at (212) 506-2275.
Sincerely,
Anna T. Pinedo, Esq.
Cc: Joseph Bonvouloir
1