Correspondence 0001213900-25-076331 from Callodine Specialty Income Fund (CIK 0002029168)
Callodine Specialty Income Fund (CIK 0002029168)
Date: Aug. 14, 2025 · CIK: 0002029168 · Accession: 0001213900-25-076331
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-280841, 811-23984
Letter
Via EDGAR Transmission Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attention: Megan Miller
Re: Callodine Specialty Income Fund (the "Fund") Initial Registration Statement on Form N-2 File Nos. 333-280841 and 811-23984
Dear Ms. Miller,
The following responds to the comment provided via telephone, in connection with the Securities and Exchange Commission staff's review of a registration statement filed by the Fund on Form N-2 under the Investment Company Act of 1940, as amended (the "1940 Act") and Securities Act of 1933. The changes to the Fund's disclosure discussed below will be reflected in the Fund's filing made pursuant to Rule 424(b)(3) of the Securities Act of 1933.
For your convenience, your comment has been summarized in bold below, and our response follows your comment.
1. Comment: Please revise the second sentence in the second paragraph on page 16 to clarify that certain expenses do not remain the same in years 2-10.
Response : The Fund will replace the aforementioned sentence with the following:
The example assumes that all distributions are reinvested at NAV and that the percentage amounts listed under annual expenses remain the same in the years shown (except that the example (i) reflects the expense limitation for the one-year period and the first year of each additional period and (ii) any warehouse and offering expenses are reflected in the first year only)).
* * * *
We trust that the foregoing is responsive to your comments. Questions and further comments concerning this filing may be directed to the undersigned at (215) 988-2959.
Sincerely,
/s/ Joshua B. Deringer
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CORRESP 1 filename1.htm Faegre Drinker Biddle & Reath LLP One Logan Square, Ste. 2000 Philadelphia, PA 19103-6996 www.faegredrinker.com August 14, 2025 Via EDGAR Transmission Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attention: Megan Miller Re: Callodine Specialty Income Fund (the "Fund") Initial Registration Statement on Form N-2 File Nos. 333-280841 and 811-23984 Dear Ms. Miller, The following responds to the comment provided via telephone, in connection with the Securities and Exchange Commission staff's review of a registration statement filed by the Fund on Form N-2 under the Investment Company Act of 1940, as amended (the "1940 Act") and Securities Act of 1933. The changes to the Fund's disclosure discussed below will be reflected in the Fund's filing made pursuant to Rule 424(b)(3) of the Securities Act of 1933. For your convenience, your comment has been summarized in bold below, and our response follows your comment. 1. Comment: Please revise the second sentence in the second paragraph on page 16 to clarify that certain expenses do not remain the same in years 2-10. Response : The Fund will replace the aforementioned sentence with the following: The example assumes that all distributions are reinvested at NAV and that the percentage amounts listed under annual expenses remain the same in the years shown (except that the example (i) reflects the expense limitation for the one-year period and the first year of each additional period and (ii) any warehouse and offering expenses are reflected in the first year only)). * * * * We trust that the foregoing is responsive to your comments. Questions and further comments concerning this filing may be directed to the undersigned at (215) 988-2959. Sincerely, /s/ Joshua B. Deringer Joshua B. Deringer