Correspondence 0001580642-24-002846 from Beacon Pointe Multi-Alternative Fund (CIK 0002004413)
Beacon Pointe Multi-Alternative Fund (CIK 0002004413)
Date: May 28, 2024 · CIK: 0002004413 · Accession: 0001580642-24-002846
AI Filing Summary & Sentiment
File numbers found in text: 333-276064, 811-23921
Letter
F 404.682.7863 May 28, 2024 VIA EDGAR ========== Alberto H. Zapata Division of Investment Management Securities and Exchange Commission Filing Desk 100 F Street, N.E. Washington, DC 20549 RE: Beacon Pointe Multi-Alternative Fund; File Nos. 333-276064 and 811-23921
Dear Mr. Zapata,
On December 15, 2023, Beacon Pointe Multi-Alternative Fund (the “Fund” or the “Registrant”) filed a registration statement under the Securities Act of 1933 on Form N-2 (the “Registration Statement”). On January 16, 2024, you provided written comments regarding the Registration Statement (the “Letter”). On April 25, 2024, the Registrant filed pre-effective amendment 1 to the Registration Statement (the “Amendment 1”) to address your comments in the Letter. On May 6, 2024, Brian Szilagyi provided oral accounting comments on the Amendment. On May 15, 2024, you provided oral comments on the Amendment 1. On May 23, 2024, the Registrant filed pre-effective amendment 2 to the Registration Statement (the “Amendment 2”) to address your comments and Mr. Szilagyi’s comments. On May 24, 2024, you provided oral comments on the Amendment 2. On May 28, 2024, Brian Szilagyi provided oral accounting comments on the Amendment 2. Please find below your comments and the Registrant's responses, which the Registrant has authorized us to make on behalf of the Registrant.
Comment 1. In “Principal Investment Strategies”, in the definition of Underlying Funds, state more clearly whether the closed-end interval funds are registered funds or may include private closed end funds.
Response. The Registrant has revised the disclosure as follows:
The Fund pursues its investment objective by strategically investing in a portfolio of U.S. registered closed-end interval funds (“Underlying Funds”) that invest in a variety of asset classes.
Comment 2. In “Principal Investment Strategies”, add a statement that the Fund won’t invest more than 15% of its assets funds exempt from registration under the 1940 Act under section 3(c)(1) or 3(c)(7) funds.
Response. The Registrant has revised the disclosure as follows:
While the Fund will primarily invest indirectly through the Underlying Funds, the Fund may also invest directly in the underlying holdings of the Underlying Funds alongside the Underlying Funds (the “Co-Investments”). The Fund may invest no more than 15% of its assets in private funds employing hedging strategies (commonly known as “hedge funds”, i.e., investment funds that would be investment companies but for the exemptions under Rule 3(c)(1) or 3(c)(7) under the 1940 Act).
1610165572.1
Accounting Comments
Comment 1. The number for “Due from Adviser for reimbursement of organizational costs” in the statement of assets and liabilities is missing. Please correct this.
Response. The Registrant will confirm that the EDGAR provider includes a completed table in the as filed version of the SAI.
Comment 2. The auditor consent incorrectly references Form N-1A instead of Form N-2. Please file a corrected consent.
Response. The auditor has provided a corrected consent, and the Registrant will file it with the next amendment.
* * *
If you have any questions or comments, please contact the undersigned at 404-736-7863. Thank you in advance for your consideration.
Sincerely,
/s/ Tanya L. Boyle
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CORRESP
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filename1.htm
DLA
Piper LLP (US)
One
Atlantic Center
1201 West Peach 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
May 28, 2024
VIA EDGAR
==========
Alberto H. Zapata
Division of Investment Management
Securities and Exchange Commission
Filing Desk
100 F Street, N.E.
Washington, DC 20549
RE: Beacon Pointe Multi-Alternative Fund; File Nos.
333-276064 and 811-23921
Dear Mr. Zapata,
On December 15, 2023, Beacon Pointe Multi-Alternative
Fund (the “Fund” or the “Registrant”) filed a registration statement under the Securities Act of 1933 on Form
N-2 (the “Registration Statement”). On January 16, 2024, you provided written comments regarding the Registration Statement
(the “Letter”). On April 25, 2024, the Registrant filed pre-effective amendment 1 to the Registration Statement (the “Amendment
1”) to address your comments in the Letter. On May 6, 2024, Brian Szilagyi provided oral accounting comments on the Amendment. On
May 15, 2024, you provided oral comments on the Amendment 1. On May 23, 2024, the Registrant filed pre-effective amendment 2 to the Registration
Statement (the “Amendment 2”) to address your comments and Mr. Szilagyi’s comments. On May 24, 2024, you provided oral
comments on the Amendment 2. On May 28, 2024, Brian Szilagyi provided oral accounting comments on the Amendment 2. Please find below your
comments and the Registrant's responses, which the Registrant has authorized us to make on behalf of the Registrant.
Comment 1. In “Principal Investment
Strategies”, in the definition of Underlying Funds, state more clearly whether the closed-end interval funds are registered funds
or may include private closed end funds.
Response. The Registrant has revised
the disclosure as follows:
The Fund pursues its investment objective
by strategically investing in a portfolio of U.S. registered closed-end interval funds (“Underlying
Funds”) that invest in a variety of asset classes.
Comment 2. In “Principal Investment
Strategies”, add a statement that the Fund won’t invest more than 15% of its assets funds exempt from registration under the
1940 Act under section 3(c)(1) or 3(c)(7) funds.
Response. The Registrant has revised
the disclosure as follows:
While the Fund will primarily invest indirectly
through the Underlying Funds, the Fund may also invest directly in the underlying holdings of the Underlying Funds alongside the Underlying
Funds (the “Co-Investments”). The Fund may invest no more than 15% of its assets in private funds
employing hedging strategies (commonly known as “hedge funds”, i.e., investment funds that would be investment companies but
for the exemptions under Rule 3(c)(1) or 3(c)(7) under the 1940 Act).
1610165572.1
Accounting Comments
Comment 1. The number for “Due
from Adviser for reimbursement of organizational costs” in the statement of assets and liabilities is missing. Please correct this.
Response. The Registrant will confirm
that the EDGAR provider includes a completed table in the as filed version of the SAI.
Comment 2. The auditor consent incorrectly
references Form N-1A instead of Form N-2. Please file a corrected consent.
Response. The auditor has provided a
corrected consent, and the Registrant will file it with the next amendment.
* * *
If you have any questions or comments, please
contact the undersigned at 404-736-7863. Thank you in advance for your consideration.
Sincerely,
/s/ Tanya L. Boyle
Tanya L. Boyle