SEC Company Response from Lord Abbett Corporate Opportunities Fund (CIK 0001855299) — Jun 30, 2021
Lord Abbett Corporate Opportunities Fund (CIK 0001855299)
Date: June 30, 2021 · CIK: 0001855299 · Accession: 0000930413-21-001272
AI Filing Summary & Sentiment
File numbers found in text: 333-255294, 811-23655
Referenced dates: June 7, 2021
Letter
VIA EDGAR Division of Investment Management 100 F Street, NE Washington, D.C. 20549 Re: Lord Abbett Special Situations Income Fund (the “Fund”) File No. 333-255294; 811-23655
Dear Ms. O’Neal,
Reference is made to the initial registration statement on Form N-2 (the “Registration Statement”) filed on April 16, 2021 with the U.S. Securities and Exchange Commission (the “Commission”) via EDGAR pursuant to the Securities Act of 1933, as amended, and the Investment Company Act of 1940, as amended, on behalf of the Fund.
This letter responds to comments you provided telephonically on June 17, 2021 regarding the Registration Statement. Pre-Effective Amendment No. 1 to the Registration Statement, which is being filed with the Commission on June 30, 2021 (the “Amendment”), reflects the changes made in response to your comments.
Capitalized terms used but not defined herein have the meanings given to them in the Registration Statement.
1. Please considering stating a policy of investing at least 80% of the Fund's assets in securities of issuers that the Fund deems to be “special situations.” See Rule 35d-1(a)(2)(i) under the Investment Company Act of 1940.
Response: The requested disclosure has been added in the Amendment.
2. Please clarify in the disclosure, as noted in your response letter dated June 7, 2021, that the Fund does not focus its analysis on any particular ESG area of consideration and does not specifically seek out issuers with “ESG characteristics,” but rather considers ESG factors where relevant or material, among other material factors, in the context of a particular investment opportunity.
Response: The requested disclosure has been added in the Amendment.
* * *
Please call me at (201) 827-2966 if you have any questions or wish to discuss our comments.
Sincerely,
/s/ Pamela P. Chen
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LORD ABBETT SPECIAL SITUATIONS INCOME FUND
90 Hudson Street
Jersey City, NJ 07302
June 30, 2021
VIA EDGAR
Ms. Deborah L. O’Neal
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Re:
Lord Abbett Special Situations Income Fund (the “Fund”)
File No. 333-255294; 811-23655
Dear Ms. O’Neal,
Reference is made to the initial
registration statement on Form N-2 (the “Registration Statement”) filed on April 16, 2021 with the U.S. Securities and Exchange
Commission (the “Commission”) via EDGAR pursuant to the Securities Act of 1933, as amended, and the Investment Company Act
of 1940, as amended, on behalf of the Fund.
This
letter responds to comments you provided telephonically on June 17, 2021 regarding the Registration Statement. Pre-Effective
Amendment No. 1 to the Registration Statement, which is being filed with the Commission on June 30, 2021 (the “Amendment”),
reflects the changes made in response to your comments.
Capitalized terms used but not
defined herein have the meanings given to them in the Registration Statement.
1. Please considering stating
a policy of investing at least 80% of the Fund's assets in securities of issuers that the Fund deems to be “special situations.”
See Rule 35d-1(a)(2)(i) under the Investment Company Act of 1940.
Response: The requested disclosure has been
added in the Amendment.
2. Please clarify in the
disclosure, as noted in your response letter dated June 7, 2021, that the Fund does not focus its analysis on any particular ESG area
of consideration and does not specifically seek out issuers with “ESG characteristics,” but rather considers ESG factors where
relevant or material, among other material factors, in the context of a particular investment opportunity.
Response: The
requested disclosure has been added in the Amendment.
* * *
Please call me at (201) 827-2966 if you have any questions or wish to
discuss our comments.
Sincerely,
/s/ Pamela P. Chen
Pamela P. Chen
Vice President and Assistant Secretary
Lord Abbett Special Situations Income Fund