Correspondence 0001213900-23-059959 from ALTI PRIVATE EQUITY ACCESS & COMMITMENTS FUND (CIK 0001759455)
ALTI PRIVATE EQUITY ACCESS & COMMITMENTS FUND (CIK 0001759455)
Date: July 26, 2023 · CIK: 0001759455 · Accession: 0001213900-23-059959
AI Filing Summary & Sentiment
Referenced dates: June 21, 2023
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 and ALTI, LLC File No. 812-15404
Dear Ms. Riegel:
This letter is in response to written comments received from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) on July 25, 2023 regarding an application for exemptive relief (the “Application”) 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. On the outside cover page and inside cover page, in the captions that indicate the requested relief, and in Section I, third paragraph, penultimate sentence (“Any of the Funds relying on…”), before the defined term “Application”, please clarify that the filed Application is the Third Amended and Restated Application.
The Fund has updated the Application as requested.
2. In the first sentence of the penultimate paragraph of Section I, in order to comply fully with comment 5 of the staff’s comment letter dated June 21, 2023 (“Previous Comment Letter”), please clarify whether the Class A Shares and Class D Shares will be subject to front-end sales charges. We note that the current language speaks to sales loads generally without differentiating between various types of sales loads.
The Fund has updated the Application as requested.
3. In the second paragraph of Section I.C., in order to comply fully with comment 7 of the Previous Comment Letter, please replace the first sentence with the following: “Shares may be subject to an early repurchase fee at a rate not to exceed 2.00 percent of the shareholder’s repurchase proceeds (‘Early Repurchase Fee’) if the interval between the date of the purchase of the shares and the valuation date with respect to the repurchase of those shares is less than one year. [5]”
The Fund has updated the Application as requested.
4. In Sections VII and VIII, please delete each occurrence of “Second Amended and Restated” before “Application”.
The Fund has updated the Application as requested.
Should you have any questions regarding this letter, please contact me at (212) 506-2275.
Sincerely,
/s/ Anna Pinedo
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ALTI Private Equity Access and Commitments Fund
July 26, 2023
VIA EDGAR AND OVERNIGHT MAIL
Laura J. Riegel, 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 and ALTI, LLC
File No. 812-15404
Dear Ms. Riegel:
This letter is in response to written comments
received from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) on July
25, 2023 regarding an application for exemptive relief (the “Application”) 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. On the outside cover page and inside cover page, in the
captions that indicate the requested relief, and in Section I, third paragraph, penultimate sentence (“Any of the Funds relying
on…”), before the defined term “Application”, please clarify that the filed Application is the Third Amended
and Restated Application.
The
Fund has updated the Application as requested.
2. In the first sentence of the penultimate paragraph of
Section I, in order to comply fully with comment 5 of the staff’s comment letter dated June 21, 2023 (“Previous Comment Letter”),
please clarify whether the Class A Shares and Class D Shares will be subject to front-end sales charges. We note that the current language
speaks to sales loads generally without differentiating between various types of sales loads.
The
Fund has updated the Application as requested.
3. In the second paragraph of Section I.C., in order to comply
fully with comment 7 of the Previous Comment Letter, please replace the first sentence with the following: “Shares may be subject
to an early repurchase fee at a rate not to exceed 2.00 percent of the shareholder’s repurchase proceeds (‘Early Repurchase
Fee’) if the interval between the date of the purchase of the shares and the valuation date with respect to the repurchase of those
shares is less than one year. [5]”
The
Fund has updated the Application as requested.
4. In Sections VII and VIII, please delete each occurrence
of “Second Amended and Restated” before “Application”.
The
Fund has updated the Application as requested.
Should you have any questions regarding this letter,
please contact me at (212) 506-2275.
Sincerely,
/s/ Anna Pinedo
Anna T. Pinedo, Esq.
Cc: Joseph Bonvouloir