Correspondence 0001580642-24-003716 from Catalyst/Perini Strategic Income Fund (CIK 0002007649)
Catalyst/Perini Strategic Income Fund (CIK 0002007649)
Date: July 17, 2024 · CIK: 0002007649 · Accession: 0001580642-24-003716
AI Filing Summary & Sentiment
File numbers found in text: 333-276546, 811-23928
Letter
Division of Investment Management F Street, N.E. Washington, D.C. 20549
Re: Catalyst Strategic Income Opportunities Fund, File Nos. 333-276546 and 811-23928
Dear Mr. Long,
On January 17, 2024, Catalyst Strategic Income Opportunities Fund (the "Fund" or the "Registrant"), filed a registration statement (the "Registration Statement") on Form N-2 and an Pre-Effective Amendment No.1 to the Registration Statement (the “Amendment”) on July 2, 2024. On July 17, 2024, you provided the following comment to the Amendment to Andrew Davalla. The Fund has authorized Thompson Hine LLP to make the response on its behalf.
Comment 1. Does the Fund hold any investments or intend to hold any investments prior to the effectiveness of its registration statement? Has the Fund entered into or does it intend to enter into any warehousing transaction for the purposes of establishing the Fund’s initial portfolio? If so, has the Fund considered Section 6.11 of Reg S-X as to whether such a warehousing transaction would constitute a fund acquisition. If so, please explain the Fund’s determination with regard to Reg S-X Section 6.11 applicability. If such a transaction does not constitute a fund acquisition, please include a recent Statement of Investments pursuant to Section 12.12 of Reg S-X in the Fund’s registration statement prior to effectiveness.
Response: The Fund does not hold any investment or intend to hold any investment prior to the effectiveness of its Registration Statement. The Fund has not entered into and does not intend to enter into any warehousing transaction for the purposes of establishing its initial investment portfolio.
If you have any questions about the responses set forth above, please contact the undersigned at 216.566.5706 or andrew.davalla@thompsonhine.com.
Best regards,
/s/ Andrew Davalla
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CORRESP
1
filename1.htm
July 17, 2024
Jeffrey
Long
U.S.
Securities and Exchange Commission
Division
of Investment Management
100
F Street, N.E.
Washington, D.C. 20549
Re: Catalyst Strategic Income Opportunities
Fund, File Nos. 333-276546 and 811-23928
Dear Mr. Long,
On January 17, 2024, Catalyst Strategic Income
Opportunities Fund (the "Fund" or the "Registrant"), filed a registration statement (the "Registration Statement")
on Form N-2 and an Pre-Effective Amendment No.1 to the Registration Statement (the “Amendment”) on July 2, 2024. On July 17,
2024, you provided the following comment to the Amendment to Andrew Davalla. The Fund has authorized Thompson Hine LLP to make the response
on its behalf.
Comment 1. Does the Fund hold any investments
or intend to hold any investments prior to the effectiveness of its registration statement? Has the Fund entered into or does it intend
to enter into any warehousing transaction for the purposes of establishing the Fund’s initial portfolio? If so, has the Fund considered
Section 6.11 of Reg S-X as to whether such a warehousing transaction would constitute a fund acquisition. If so, please explain the Fund’s
determination with regard to Reg S-X Section 6.11 applicability. If such a transaction does not constitute a fund acquisition, please
include a recent Statement of Investments pursuant to Section 12.12 of Reg S-X in the Fund’s registration statement prior to effectiveness.
Response: The Fund does not hold any investment
or intend to hold any investment prior to the effectiveness of its Registration Statement. The Fund has not entered into and does not
intend to enter into any warehousing transaction for the purposes of establishing its initial investment portfolio.
If you have any questions about the responses
set forth above, please contact the undersigned at 216.566.5706 or andrew.davalla@thompsonhine.com.
Best regards,
/s/ Andrew Davalla
Andrew Davalla