Correspondence 0001580642-24-007535 from CANTOR FITZGERALD INFRASTRUCTURE FUND (CIK 0001902944)
CANTOR FITZGERALD INFRASTRUCTURE FUND (CIK 0001902944)
Date: Dec. 12, 2024 · CIK: 0001902944 · Accession: 0001580642-24-007535
AI Filing Summary & Sentiment
File numbers found in text: 333-262031, 811-23773
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission Public Filing Desk 100 F Street, N.E. Washington, D.C. 20549 Re: Cantor Fitzgerald Infrastructure Fund, File Nos. 333-262031 and 811-23773
Dear Mr. Eskildsen:
This letter responds to oral comments on December 4, 2024 made pursuant to Section 408 of the Sarbanes-Oxley Act of 2002 by the staff of the Division of Investment Management (the “Staff”) of the U.S. Securities and Exchange Commission in a telephone conversation with the undersigned regarding the Certified Shareholder Report on Form N-CSR for the fiscal year ended March 31, 2024, for the Cantor Fitzgerald Infrastructure Fund (the “Fund” or “Registrant”) and the Form N-PORT. For your convenience, the substance of each of the Staff’s comment has been restated below. The response of the Registrant to the comment immediately follows the restated comment.
Comment 1. In Item C.8 of the N-PORT filings, it indicates that the level of the fair value hierarchy of the Fund’s portfolio are level 1 securities. The response should be “N/A” because the NAV is calculated using the practical expedient method. Please correct it going forward.
Response. The Registrant will correct the response, when applicable, going forward.
Comment 2. In the N-CSR, because private investment funds in which the Fund invests are restricted securities, on a going forward basis, please add disclosure regarding the acquisition date and cost of these securities in accordance with Reg S-X 12-12, Footnote 8.
Response. The Registrant will correct the disclosure going forward.
Comment 3. In statement of assets and liabilities in the N-CSR, on a going forward basis, add a line item regarding unfunded commitments in accordance with Reg S-X 6-04.15.
Response. The Registrant will correct the disclosure going forward.
If you have any questions concerning this filing, please contact Tanya Boyle at 404-736-7863.
Sincerely,
December 12, 2024
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DLA Piper LLP (US)
One Atlantic
Center
1201 West Peachtree Street
Suite 2900
Atlanta, Georgia 30309-3449
www.dlapiper.com
Tanya L. Boyle
tanya.boyle@us.dlapiper.com
T 404.736.7863
F 404.682.7863
December 12, 2024
VIA EDGAR
Chad Eskildsen
Division of Investment Management
Disclosure Review and Accounting Office
Securities and Exchange Commission
Public Filing Desk
100 F Street, N.E.
Washington, D.C. 20549
Re: Cantor Fitzgerald Infrastructure Fund, File Nos. 333-262031 and
811-23773
Dear Mr. Eskildsen:
This letter responds to oral comments on December 4,
2024 made pursuant to Section 408 of the Sarbanes-Oxley Act of 2002 by the staff of the Division of Investment Management (the “Staff”)
of the U.S. Securities and Exchange Commission in a telephone conversation with the undersigned regarding the Certified Shareholder Report
on Form N-CSR for the fiscal year ended March 31, 2024, for the Cantor Fitzgerald Infrastructure Fund (the “Fund” or “Registrant”)
and the Form N-PORT. For your convenience, the substance of each of the Staff’s comment has been restated below. The response of
the Registrant to the comment immediately follows the restated comment.
Comment 1. In Item C.8 of the N-PORT filings,
it indicates that the level of the fair value hierarchy of the Fund’s portfolio are level 1 securities. The response should be “N/A”
because the NAV is calculated using the practical expedient method. Please correct it going forward.
Response. The Registrant will correct the response,
when applicable, going forward.
Comment 2. In the N-CSR, because private investment
funds in which the Fund invests are restricted securities, on a going forward basis, please add disclosure regarding the acquisition date
and cost of these securities in accordance with Reg S-X 12-12, Footnote 8.
Response. The Registrant will correct the disclosure
going forward.
Comment 3. In statement of assets and liabilities
in the N-CSR, on a going forward basis, add a line item regarding unfunded commitments in accordance with Reg S-X 6-04.15.
Response. The Registrant will correct the disclosure
going forward.
If you have any questions concerning this filing, please contact Tanya Boyle
at 404-736-7863.
Sincerely,
December 12, 2024
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/s/ DLA Piper LLP
DLA Piper LLP