Correspondence 0001133228-24-000344 from Coller Secondaries Private Equity Opportunities Fund (CIK 0001969180)
Coller Secondaries Private Equity Opportunities Fund (CIK 0001969180)
Date: Jan. 22, 2024 · CIK: 0001969180 · Accession: 0001133228-24-000344
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File numbers found in text: 333-272265, 811-23879
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Simpson
Thacher & Bartlett LLP
425
lexington avenue
new
york, ny 10017-3954
telephone: +1-212-455-2851
December 22, 2023
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.W.
Washington, D.C. 20549
Attn: Karen Rossotto and Jeff Long
Re:
Coller Secondaries Private Equity Opportunities Fund
File Nos. 811-23879 and 333-272265
Ladies and Gentlemen:
On behalf of Coller Secondaries
Private Equity Opportunities Fund (formerly, Coller Secondaries Private Equity Fund) (the “Fund”), we are providing the following
responses to supplemental comments received from the staff (the “Staff”) of the Division of Investment Management of the U.S.
Securities and Exchange Commission (the “Commission”) by telephone on December 18, 2023 and December 20, 2023 (the “Supplemental
Comments”), relating to the Fund’s registration statement on Form N-2 under the Securities Act of 1933, as amended (the “1933
Act”) and the Investment Company Act of 1940, as amended (the “1940 Act”), filed with the Commission on May 30, 2023
(the “Registration Statement”). The Fund intends to file Pre-Effective Amendment No. 1 (the “Amendment”) to the
Registration Statement, which will include revisions in response to the Supplemental Comments and revisions to otherwise update disclosure.
For convenience of reference,
the Supplemental Comments have been reproduced herein. All capitalized terms used but not defined in this letter have the meanings given
to them in the Registration Statement.
Predecessor Fund
1. Supplemental Comment: Please revise the disclosure to clarify that there is no guarantee that the
contemplated transaction with the Predecessor Fund will be approved by the Board or by the Predecessor Fund’s general partner. Please
also revise the disclosure to indicate how C-SPEF will invest the proceeds from the sale of Shares of C-SPEF in the event that the contemplated
transaction with the Predecessor Fund does not occur.
Response: The disclosure will be
revised in the Amendment.
BEIJING
Brussels
HONG KONG
Houston
LONDON
Los Angeles
Palo Alto
SÃO PAULO
TOKYO
Washington, D.C.
2
2. Supplemental Comment: Regarding the audited financial statements of the Predecessor Fund to be
filed in a post-effective amendment to the Registration Statement, as contemplated by Rule 6-11 of Regulation S-X, please explain in correspondence
which reporting period(s) will be included in such financial statements.
Response: The Fund currently anticipates
that the audited financial statements of the Predecessor Fund contemplated by Rule 6-11 of Regulation S-X will include the three-month
and since-inception periods ended March 31, 2024.
_______________________
Please call me at (212) 455-2851 with any questions
you may have regarding this filing or if you wish to discuss the above responses.
Very truly yours,
/s/ Nathan D. Somogie
Simpson Thacher & Bartlett LLP
cc: Jay Williamson, Securities and Exchange Commission
Richard Jason Alexander Elmhirst, Esq., Coller Private Market
Secondaries Advisors, LLC
Alexander Wahllof-Malinconico, Coller Private Market Secondaries
Advisors, LLC
Josh Schnurman, Coller Private Market Secondaries Advisors, LLC
Radin Ahmadian, Esq., Coller Private Market Secondaries Advisors,
LLC
Rajib Chanda, Esq., Simpson Thacher & Bartlett LLP
John Fitzgerald, Esq., Simpson Thacher & Bartlett LLP
Benjamin Ruano, Esq., Simpson Thacher & Bartlett LLP