SecProbe.io

CORRESP
1
filename1.htm

CORRESP

 SIDLEY AUSTIN LLP

 787 SEVENTH AVENUE

NEW YORK, NY 10019

 +1 212 839 5300

+1 212 839 5599 FAX

AMERICA • ASIA PACIFIC • EUROPE

 +1 212 839 5969

CTEODORO@SIDLEY.COM

 February 27, 2026

VIA EDGAR

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Attention: Brian Szilagyi, CPA

 Senior Staff Accountant, Division
of Investment Management

Re:
 Annual Reports of the Funds Listed on Appendix A

Dear Mr. Szilagyi:

 On behalf of the funds
set forth in Exhibit A (each, a “Fund” and collectively, the “Funds”), this letter responds to comments provided by the staff of the Division of Investment Management (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) on January 29, 2026 regarding the Annual Reports to Shareholders on Form N-CSR (each, an “Annual Report”) and the Annual Reports for
Registered Investment Companies on Form N-CEN (each, a “Form N-CEN” and together with the Annual Reports, the “Reports”) of each Fund.

For your convenience, the substance of the Staff’s comments has been restated below. We have discussed the Staff’s comments with
representatives of the Funds and UBS Asset Managers of Puerto Rico (the “Adviser”). Each Fund’s joint or individual responses to each comment, as applicable, are set out immediately under the restated comment. Please note that we
have not independently verified information provided by the Funds. Unless otherwise indicated, defined terms used herein have the meanings set forth in the relevant Report(s).

COMMENT LETTER

1.
 Comment: With respect to Short Term Investment Fund for Puerto Rico Residents, Inc., the registration
statement does not appear to have been updated not more than 120 days after the close of the fiscal year in accordance with Rule 8b-16 under the Investment Company Act of 1940, as amended (the
“Investment Company Act”). Please confirm how this will be corrected and describe whether any capital shares transactions were executed on a stale prospectus.

Response: Under rule 8b-16, the registration statement for the Short Term Investment Fund for
Puerto Rico Residents, Inc. (“STIF”) was required to be filed by 5:00 p.m. (Eastern) on October 28, 2025, but was filed and accepted after hours on that date. As such, the registration statement was not effective until
October 29, 2025. The delay in filing was the result of administrative delays with respect to sign-offs from certain reviewing parties. No capital share transactions were executed on a stale prospectus. STIF and the Investment Adviser have
implemented additional policies and procedures and corrective measures to ensure that this delay does not occur with future filings.

 Sidley Austin (NY) LLP is
a Delaware limited liability partnership doing business as Sidley Austin LLP and practicing in affiliation with other Sidley Austin partnerships.

2.
 Comment: With respect to Short Term Investment Fund for Puerto Rico Residents, Inc., the Fund reports
that the securities held by the Fund are self-custodied by an affiliate of the Adviser, as such Rule 17f-2 certificates by the independent auditors and related reporting are required to be filed. Per review of
the filing history, it appears that there is one report missing for the fiscal year ended June 30, 2025. Please file any missing reports or provide a reason why the reports are not filed. Please explain what controls will be implemented to
ensure that all future filings will be made in a timely manner.

 Response: STIF’s independent auditors filed
a Form N-17f-2 for the fiscal year ended June 30, 2025, with the Commission via EDGAR on December 16, 2025. As this was the third filing relating to an
examination during the fiscal year ended June 30, 2025, the Fund does not believe any reports are missing.

3.
 Comment: With respect to Multi-Select Securities Fund for Puerto Rico Residents, Inc. the Notes to the
Financial Statements state that “the Fund has suspended the trading of its securities pending registration under the Securities Act of 1933, as amended.” However, item B.7. to the registrant’s March 31, 2025, Form N-CEN is marked “yes.” In correspondence, please address the apparent discrepancy in this reporting.

Response: “Yes” in response to item B.7. in the relevant Form N-CEN was marked in
error.

4.
 Comment: With respect to Multi-Select Securities Fund for Puerto Rico Residents, please discuss in
correspondence why the Fund has not included the following required tax disclosure: “the company’s status as a regulated investment company as defined in subtitle A, chapter 1, subchapter M of the Internal Revenue Code, as
amended.” Going forward, please ensure future financial statements include this required disclosure.

 Response:
The Fund does not intend to qualify as a regulated investment company as defined in subtitle A, chapter 1, subchapter M of the Internal Revenue Code, as amended, and therefore has not included the language described in the comment above. The
Fund will include the following disclosure in future financial statements: “the Fund does not intend to qualify as a regulated investment company as defined in subtitle A, chapter 1, subchapter M of the Internal Revenue Code, as
amended.”

5.
 Comment: The title of the individuals signing the certifications contained in Form N-CSR does not explicitly include the title of principal execute officer or principal financial officer. Please confirm in correspondence that the individuals who signed the certifications provided with the filing
are the principal executive officer and/or principal financial officer and going forward please confirm that such titles will be included in the signed certification.

Response: The Funds confirm the President and Treasurer hold responsibilities consistent with the Commission’s reference to
principal executive officer and principal financial officer, respectively. The Funds note that an officer’s title is determined in accordance with state law and the Funds’ organizational documents. Therefore, the Funds respectfully
decline to change the titles in future N-CSR filings.

6.
 Comment: With respect to U.S. Monthly Income Fund for Puerto Rico Residents, Inc., the amounts disclosed
in the purchases and sales of investments section of the Notes to Financial Statements do not correlate with the portfolio turnover disclosed in the Financial Highlights. Please discuss in correspondence how portfolio turnover has been calculated
and consider disclosures that would add clarity to the portfolio turnover amount disclosed in the Financial Highlights.

 2

 Response: Portfolio turnover is calculated based on Form N-1A instructions, namely by taking the lesser of amounts of purchases or sales of portfolio securities for the fiscal year divided by the monthly average of the value of the portfolio securities owned by the Fund
during the fiscal year. Since for the period covered by the Fund’s annual report the Fund did not have any purchases, the portfolio turnover rate was 0.00%. Going forward, if there are no purchases or sales of portfolio securities during
the reporting period the Fund will disclose such in the Notes to Financial Statements.

7.
 Comment: With respect to U.S. Monthly Income Fund for Puerto Rico Residents, Inc., the Fund has been
identified in the Annual Report as a non-diversified fund, however it appears the Fund is operating as a diversified fund. Please confirm that the Fund continues to qualify as a
non-diversified fund and if the Fund has been operating as a diversified fund for more than three years then confirm that the Fund will receive shareholder approval prior to changing its status to non-diversified.

 Response: The Fund is operating as a diversified fund and
therefore will be redesignated as such. This will be reflected in future registration statements and the “Non-Diversification Risk” disclosure will be removed from the principal risk
factors.

8.
 Comment: With respect to U.S. Monthly Income Fund for Puerto Rico Residents, Inc., Form N-CEN item B.22. for the period ended December 31, 2024, indicates that the Fund had a NAV error during the period, however the Staff did not locate disclosure in the Financial Statements relating to such
error. Please describe the nature and circumstances of the error and associated internal control implications, mitigating actions, and amounts reimbursed, if any. In addition, if amounts have been reimbursed, please explain citing applicable
US GAAP, Regulation S-X and other accounting guidance, why the Fund has not disclosed these reimbursement amounts in its Financial Statements.

Response: A security exchange was not posted on settlement date causing a difference in total unrealized gain/loss. One client
transaction was placed and it was adjusted prior to settlement date and therefore no reimbursements were necessary. Due to the lack of materiality, this was not disclosed in the Fund’s financial statements.

9.
 Comment: With respect to Multi-Select Securities Fund for Puerto Rico Residents it appears there is no
disclosure regarding Accounting Standards Update 2023-07, Topic 280. This guidance was applicable to all public entities for fiscal years beginning after December 15, 2023, and interim periods within
fiscal years beginning after December 15, 2024. In future reports please include the information required by the ASU.

Response: Future reports will include the information required by Accounting Standards Update
2023-07, Topic 280 – Operating Segments.

10.
 Comment: With respect to Short Term Investment Fund for Puerto Rico Residents, Inc., we note that in
response to a comment given during the most recent SOX review the registrant stated the fund will clarify in future reports that the amortized cost method was used only with respect to securities that have a maturity of 60 days or less. The staff
does not believe this clarification has been made in the Notes to Financial Statements. Going forward, please include a description of the valuation techniques used and the fair value measurement of those assets measured at amortized cost in
compliance with ASBY 820-10-50-2-bbb(1).

 3

 Response: The omission of disclosure indicating that valuations using the amortized
cost method were used only with respect to securities that have a maturity of 60 days or less was in error. STIF’s valuation techniques and the fair value measurement of those assets measured at amortized cost in compliance with ASBY 820-10-50-2-bbb(1) will be disclosed in reports going forward.

11.
 Comment: With respect to Puerto Rico Residents Tax-Free Fund V,
Inc., Tax-Free Fixed Income Fund IV for Puerto Rico Residents, Inc., Tax-Free Fixed Income Fund V for Puerto Rico Residents, Inc.,
Tax-Free Fixed Income Fund VI for Puerto Rico Residents, Inc. and GNMA & US Government Target Maturity Fund for Puerto Rico Residents, Inc., ASBY ASC 946-205-45-1 requires investment companies registered with the Commission to present financial highlights for the latest 5 fiscal years. Please discuss in
correspondence how the fund has complied with this requirement.

 Response: In accordance with Form N-2 instructions, the Funds have reported financial highlights since 2021, the year the Funds became registered under the 1940 Act.

12.
 Comment: The Staff noted that total return is shown in the Financial Highlights for both market price
and NAV. In future reports for periods in which shares of a Fund are unlisted, please include total return based only on NAV.

Response: Future reports will include total return based only on NAV for Fund shares that are unlisted.

13.
 Comment: With respect to Puerto Rico Residents Tax-Free Fund V,
Inc., Form N-CEN item D.8. does not appear to be calculated properly. Please ensure this item is correctly reported in future filings on Form N-CEN.

 Response: The reported fee for that period was based on gross assets. We confirm future calculations will use the
correct method (net assets).

14.
 Comment: With respect to Tax-Free Fixed Income Fund IV for
Puerto Rico Residents, Inc., Tax-Free Fixed Income Fund V for Puerto Rico Residents, Inc., and GNMA & US Government Target Maturity Fund for Puerto Rico Residents, Inc., registrant marks Form N-CEN item B.7. as “yes.” Please either confirm this response or correct it as necessary in future Form N-CEN filings.

Response: “Yes” in the Forms N-CEN indicated above was marked in error. Going
forward, “No” will be marked for Funds that are not registered under the Securities Act of 1933, as amended.

15.
 Comment: With respect to Puerto Rico Residents Tax-Free Fund II,
Inc., Puerto Rico Residents Tax-Free Fund III, Inc. and Puerto Rico Residents Tax-Free Fund IV, Inc., Form N-CEN should be filed
not later than 75 days after the close of the fiscal year for which the report is being prepared. The Staff has noted that the registrant has yet to file its most recent Form N-CEN for the fiscal year ended
August 31, 2025. Please file Form N-CEN as soon as possible and in correspondence please explain the reasons why Form N-CEN was not timely filed as well as any new
controls put into place to ensure timely filings in the future.

 4

 Response: The Forms N-CEN for the Funds
identified in this Comment 15 were filed with the Commission on February 10, 2026.

 During the transition of the Funds’ fund
administration services from SS&C to State Street Bank (“SSB”), there was a miscommunication that led to a delay in filing the above referenced N-CENs due to be filed on November 14, 2025.
These were eventually filed on February 10, 2026. UBS had assumed that the financial reporting team at SSB had provided the necessary financials to the SSB N-CEN team to prepare the reports. However, UBS
was notified after the fact that the initiation of this process was required by the client (UBS) and not SSB.

 To avoid such an issue in
the future and to ensure a smoother process, UBS and SSB have implemented an improved communication process. This new plan involves better coordination and explicit instructions and approvals for all tasks.

16.
 Comment: With respect to Puerto Rico Residents Tax-Free Fund II,
Inc., Puerto Rico Residents Tax-Free Fund III, Inc., Puerto Rico Residents Tax-Free Fund IV, Inc., Puerto Rico Residents Tax-Free
Fund V, Inc. and Puerto Rico Residents Bond Fund I, please discuss in correspondence why the Fund has not included the following required tax disclosure: the tax basis components of dividends paid for the 2 most recent fiscal year ends. Please
ensure future financial statements include the required ASC 946-505-50-5 disclosures.

Response: The tax basis component of dividends paid from the 2 most recent fiscal year ends will be included in future financial
statements.

17.
 Comment: With respect to Tax-Free Fixed Income Fund for Puerto
Rico Residents, Inc., Tax-Free Fixed Income Fund III for Puerto Rico Residents, Inc., Tax-Free High Grade Portfolio Bond Fund II for Puerto Rico Residents, Inc., Tax-Free High Grade Portfolio Target Maturity Fund for Puerto Rico Residents, Inc. and Tax Free Target Maturity Fund for Puerto Rico Residents, Inc., please provide supplemental details about the cyber-attack that
impacted the Funds’ accounting system beginning on August 11, 2025, and describe any associated internal control implications and mitigating actions, including financial restatements and NAV error corrections. Please further include a
description of the qualitative and quantitative impact to the Funds’ Financial Statements, if any.

 Response:
UBS has been actively working on remediation and reconnection efforts following the cybersecurity incident that impacted Linedata in August 2025. Linedata is a third-party service provider providing software for mutual fund pricing and
accounting services for UBS Trust Company of Puerto Rico (“UBSTCPR”), which acts as Fund Administrator for the funds. To ensure the utmost precaution, UBSTCPR had suspended all c