SEC Company Response from RiverNorth Flexible Municipal Income Fund, Inc. (RFM) (CIK 0001790177) (RFM) — Mar 18, 2020
RiverNorth Flexible Municipal Income Fund, Inc. (RFM) (CIK 0001790177)
Date: March 18, 2020 · CIK: 0001790177 · Accession: 0001398344-20-006216
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-234122, 811-23481
Letter
Via EDGAR Correspondence Filing Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 File Nos. 333-234122, 811-23481
Re: RiverNorth Flexible Municipal Income Fund, Inc. (the “Fund”)
Dear Mr. Sutcliffe:
We received your comment provided by telephone conference on March 16, 2020 regarding the Registration Statement on Form N-2 for the above captioned Fund (the “Registration Statement”). This letter serves to respond to your comment.
Prospectus—Risks
1. Please update the risk disclosure in the Prospectus to address the risks associated with the current pandemic.
Response: The Fund notes that risks associated with various uncertainties and events that may occur around the world, such as the ongoing pandemic, are covered under “Risks—Market Disruption, Geopolitical and Climate Change Risks.” The Fund will, in a final pre-effective amendment to the Registration Statement, incorporate the following revisions to the first paragraph of such disclosure to make the requested clarification:
The Fund and Underlying Funds (as well as their service providers) may be adversely affected by uncertainties and events around the world, such as epidemics and pandemics, including the spread of infectious illness or other public health issues, natural disasters, terrorism and other conflicts, social unrest, political developments, and changes in government policies, taxation, restrictions on foreign investment and currency repatriation, currency fluctuations and other developments in the laws and regulations of the countries in which they are invested. The Fund cannot predict the effects or likelihood of such events in the future on the U.S. and world economies, the value of the Common Shares or the NAV of the Fund. Assets of The issuers of securities, including those held in the Fund’s or an Underlying Fund’s portfolio, could be direct targets, or indirect casualties, of an act of terrorismmaterially impacted by such events which may, in turn, negatively affect the value of such securities or such issuers’ ability to make interest payments or distributions to the Fund.
* * * * * * * *
We appreciate your prompt attention to this Registration Statement. If you have any questions or comments or would like to discuss our responses to your questions, please feel free to contact E. Roy Kim at (312) 845-3850 or the undersigned at (312) 845-3273.
Very truly yours,
Chapman and Cutler LLP
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CORRESP
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filename1.htm
March 18, 2020
Via EDGAR Correspondence
Filing
Ryan Sutcliffe
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
RiverNorth Flexible Municipal Income Fund, Inc. (the “Fund”)
File Nos. 333-234122, 811-23481
Dear Mr. Sutcliffe:
We received your comment provided by telephone
conference on March 16, 2020 regarding the Registration Statement on Form N-2 for the above captioned Fund (the “Registration
Statement”). This letter serves to respond to your comment.
Prospectus—Risks
1. Please update the risk disclosure in the Prospectus to address the risks associated with the
current pandemic.
Response: The Fund notes that
risks associated with various uncertainties and events that may occur around the world, such as the ongoing pandemic, are covered
under “Risks—Market Disruption, Geopolitical and Climate Change Risks.” The Fund will, in a final pre-effective
amendment to the Registration Statement, incorporate the following revisions to the first paragraph of such disclosure to make
the requested clarification:
The Fund and Underlying Funds (as
well as their service providers) may be adversely affected by uncertainties and events around the world, such as epidemics
and pandemics, including the spread of infectious illness or other public health issues, natural disasters, terrorism and
other conflicts, social unrest, political developments, and changes in government policies, taxation, restrictions on foreign
investment and currency repatriation, currency fluctuations and other developments in the laws and regulations of the countries
in which they are invested. The Fund cannot predict the effects or likelihood of such events in
the future on the U.S. and world economies, the value of the Common Shares or the NAV of the Fund. Assets
of The issuers of securities, including those held in the Fund’s or an Underlying Fund’s
portfolio, could be direct targets, or indirect casualties, of an act of terrorismmaterially
impacted by such events which may, in turn, negatively affect the value of such securities or such issuers’ ability to make
interest payments or distributions to the Fund.
* * * * * * * *
We appreciate your prompt
attention to this Registration Statement. If you have any questions or comments or would like to discuss our responses to your
questions, please feel free to contact E. Roy Kim at (312) 845-3850 or the undersigned at (312) 845-3273.
Very truly yours,
Chapman and Cutler LLP
By
/s/ Walter Draney
Walter Draney
cc: Marcus L. Collins, Esq.; RiverNorth Capital
Management, LLC.
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