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Letter Text
Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615)
CIK: 0001677615  ·  File(s): 333-283469, 811-23174  ·  Started: 2025-07-16  ·  Last active: 2025-07-16
Orphan - no UPLOAD in window 1 company response(s) Low - unmatched response
CR Company responded 2025-07-16
Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615)
Regulatory Compliance Financial Reporting Internal Controls
File Nos in letter: 333-283469, 811-23174
Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615)
CIK: 0001677615  ·  File(s): 333-231065, 811-23174  ·  Started: 2020-07-20  ·  Last active: 2020-07-20
Orphan - no UPLOAD in window 1 company response(s) Low - unmatched response
CR Company responded 2020-07-20
Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615)
File Nos in letter: 333-231065, 811-23174
Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615)
CIK: 0001677615  ·  File(s): 333-231065, 811-23174  ·  Started: 2020-07-15  ·  Last active: 2020-07-15
Orphan - no UPLOAD in window 1 company response(s) Low - unmatched response
CR Company responded 2020-07-15
Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615)
File Nos in letter: 333-231065, 811-23174
DateTypeCompanyLocationFile NoLink
2025-07-16 Company Response Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615) Warrendale, PA N/A
Regulatory Compliance Financial Reporting Internal Controls
Read Filing View
2020-07-20 Company Response Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615) Warrendale, PA N/A Read Filing View
2020-07-15 Company Response Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615) Warrendale, PA N/A Read Filing View
DateTypeCompanyLocationFile NoLink
No SEC comment letters found.
DateTypeCompanyLocationFile NoLink
2025-07-16 Company Response Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615) Warrendale, PA N/A
Regulatory Compliance Financial Reporting Internal Controls
Read Filing View
2020-07-20 Company Response Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615) Warrendale, PA N/A Read Filing View
2020-07-15 Company Response Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615) Warrendale, PA N/A Read Filing View
2025-07-16 - CORRESP - Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615)
CORRESP
 1
 filename1.htm

 FEDERATED HERMES PROJECT AND TRADE FINANCE TENDER
FUND

 Federated Hermes Funds

 4000 Ericsson Drive
Warrendale, Pennsylvania 15086-7561

 July 16, 2025

 Mr. Mark Cowan

 U.S. Securities and Exchange Commission

 Division of Investment Management

 100 F Street, N.E.

 Washington, DC 20549

 	RE:	FEDERATED HERMES PROJECT
AND TRADE FINANCE TENDER FUND (the "Registrant" or the "Fund")

 1933 Act File No. 333-283469

 1940 Act File No. 811-23174

 Dear Mr. Cowan:

 The Registrant is filing this
correspondence in response to comments of the Staff of the Securities and Exchange Commission (the "Staff") provided on June
26, 2025 with respect to the Fund's Post-Effective Amendment No. 1 to its registration statement on Form N-2 under the Securities
Act of 1933, as amended, which also serves as Amendment No. 29 to its registration statement under the Investment Company Act of 1940,
as amended (the "1940 Act"), submitted by the Fund on May 9, 2025 (the "Registration Statement"). We believe that
the disclosure changes to the Registration Statement and supplemental responses discussed in this letter are fully responsive to the comments
and resolve the matters raised.

 As previously discussed, the
Fund intends to file an amended Registration Statement reflecting the responses herein and updated financial information.

 COMMENT 1. PROSPECTUS COVER PAGE – PORTFOLIO
MANAGEMENT STRATEGIES

 In the Fund's 80% policy disclosed in this
section, it states that "Derivative investments made by the Fund are included within the Fund's 80% policy and are calculated
at market value." The Staff notes that the Fund could consider using notional value instead of market value.

 RESPONSE: The Registrant is aware that the
recent amendments to Rule 35d-1 under the 1940 Act (the Names Rule) will require funds to use the notional value of derivatives instruments,
rather than the market value, for purposes of determining the value of a fund's assets pursuant to its 80% policy. Prior to
the compliance date, the Registrant intends to make all necessary changes to reflect the use of notional value as part of a complex-wide
compliance change. However, at this time, the Registrant is not making any changes to its use of market value.

 COMMENT 2. PROSPECTUS – REPURCHASES OF
SHARES BY THE FUND

 Rule 14e-8 under the Securities Exchange Act of
1934, as amended, prohibits announcements of tender offers without the intention to commence such offers within a reasonable time.
Please revise the registration statement to limit the discussion of tender offers to general information like how tender offers will be
funded, any general frequency ( i.e. , quarterly, semi-annually, annually, etc.), the effect that share repurchases and related financings
might have on expense ratios and portfolio turnover, the ability of the Fund to achieve its investment objectives, and potential tax consequences
to investors. We believe that specific procedures that the Fund currently intends to follow at the time it makes a tender offer, such
as how the price to be paid for tendered shares will be determined, how long the offer will remain open, and when payment will be made
are more appropriate to disclose in the tender offer documents sent to investors when an offer is made.

 RESPONSE: The Registrant understands and
appreciates the Staff's comment reflecting its current interpretation under the tender offer rules and the discretion it affords
the Registrant's Board in determining the size of the Fund's repurchase offers and the timing within which the Fund will repurchase
Shares and remit the repurchase price after the expiration date of the repurchase offer, and then disclose such determinations at the
time the repurchase offer is made (rather than in the Fund's prospectus).

 The Registrant will update its Registration Statement
to remove the noted concepts and focus tender offer related disclosure on the specific procedures that the Registrant intends to follow
at the time it makes a tender offer consistent with the representative disclosure edits included below (additions bold and underlined
and deletions struck).

 REPURCHASE OF SHARES BY THE FUND

 Because the Fund is a closed-end fund,
shareholders do not have the right to require the Fund to repurchase any or all of their Shares. At the discretion of the Board and provided
that it is in the best interests of the Fund and Shareholders to do so, the Fund intends to provide a limited degree of liquidity to the
Shareholders by conducting repurchase offers generally quarterly (or more or less frequently as determined by the Board in its discretion).
In each repurchase offer, the Fund may offer to repurchase its Shares at their NAV on the relevant valuation date (each, a "Valuation
Date"), which will occur on or before the expiration date of the repurchase offer (the "Expiration Date"). Each repurchase
offer ordinarily will be limited to the repurchase of approximately 5-15% of the net asset value of the Fund, although the Board can determine
to authorize the Fund to repurchase in excess of 15% of the net asset value of the Fund in its discretion . Shareholders
should be aware that the Fund is likely to offer to repurchase only a limited percentage of Shares at the Board's discretion (for example,
5-15% of the net asset value of the Fund), potentially resulting in limited liquidity for any particular Shareholder desiring to participate
in a repurchase offer. The Fund will disclose the percentage of net assets of the Fund eligible to be repurchased at the time the repurchase
offer is made. If the value of Shares tendered for repurchase exceeds the value the Fund intended to repurchase, the Fund, in
its sole discretion, may: (a) accept the additional Shares permitted to be accepted pursuant to Rule 13e-4(f) under the Exchange Act of
1934, as amended (the "Exchange Act"); or (b) determine to repurchase less than the full number of Shares tendered. In the
event less than the full number of Shares tendered will be repurchased, Shareholders will have their Shares repurchased on a pro rata
basis, and tendering Shareholders will not have all of their tendered Shares repurchased by the Fund. Shareholders tendering Shares for
repurchase will be asked to give written notice of their intent to do so as soon as practicable and in any event by no later than the
date specified in the notice describing the terms of the applicable repurchase offer (i.e., the Expiration Date) . The
Fund will not accept any repurchase request received by it or its designated agent after such date. Repurchases of Shares by the Fund
are subject to Rule 13e-4 under the Exchange Act, and will be made only in accordance with such rule. See "Repurchases and
Transfers of Shares."

 The Expiration Date will be a
date set by the Board occurring no sooner than twenty (20) business days after the commencement date of the repurchase offer and at least
ten (10) business days from the date that notice of an increase or decrease in the percentage of the securities being sought or consideration
offered is first published, sent or given to Shareholders. The Expiration Date may be extended by the Fund in its sole discretion. The
Fund will not accept any repurchase request received by it or its designated agent after the Expiration Date.

 The Fund has the right to repurchase Shares
from a Shareholder if the Board determines that the repurchase is in the best interests of the Fund or upon the occurrence of certain
events specified in the Fund's Declaration of Trust.

 The Fund will repurchase Shares
and remit the repurchase price to Shareholders within five (5) business days after the Expiration Date. The Fund's
Board will determine, in its discretion, the period within which the Fund will repurchase Shares and remit the repurchase price after
the expiration of the repurchase offer, and such period will be disclosed to Shareholders at the time a repurchase offer is made.

 COMMENT 3. PROSPECTUS - SUMMARY OF FUND EXPENSES

 In footnote 5 of the fee table, it is disclosed
that total expenses (after waivers and/or reimbursements) for the Institutional Shares and the Service Shares will not exceed 0.40% and
0.50%, respectively. Why are these amounts in footnote 5 less than the "Total Annual Fund Operating Expenses After Fee Waiver and/or
Expense Reimbursements" line in the fee table (0.42% and 0.52%, respectively)?

 RESPONSE: The Registrant confirms that the
total expenses disclosed are consistent with the fee limit language in Footnote 5. The 2 basis points difference between the "Fee
Limit" and the "Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursements" figures is due
to 1 basis point of "Acquired Fund Fees and Expenses" and 1 basis point for "interest expense" and "certain
legal fees related to specific investments" included within "Other Expenses," which are all outside of the Fund's
Fee Limit as addressed in Footnote 5.

 If you have any questions on
the enclosed material, please contact me at Mark.Thompson@FederatedHermes.com or(412)
288-4429.

 Very truly yours,

 /s/ Mark R. Thompson

 Mark R. Thompson

 Paralegal Manager
2020-07-20 - CORRESP - Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615)
CORRESP
1
filename1.htm

FEDERATED HERMES PROJECT AND TRADE FINANCE
TENDER FUND

4000 Ericsson Drive

Warrendale, Pennsylvania 15086-7561

July 20, 2020

Mr. Mark Cowan

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549-4720

    RE:

        FEDERATED HERMES PROJECT AND TRADE FINANCE TENDER FUND (the “Registrant”)

        1933 Act File No. 333-231065

        1940 Act File No. 811-23174

Dear Mr. Cowan:

The Registrant is filing this correspondence
to respond to further comments of the Staff of the Securities and Exchange Commission (the “Staff”) provided on July
17, 2020, regarding its response to Comment #4 in its July 15, 2020 Correspondence that responded to Staff comments on its Post-Effective
Amendment No. 1 under the Securities Act of 1933 and Amendment No. 10 under the Investment Company Act of 1940 to the Form N-2
Registration Statement of the above-referenced Registrant filed on May 13, 2020.

COMMENT 4. Prospectus – Risk
Factors – Interest Rate Risk

The Staff re-issues its comment regarding the Registrant’s
“Interest Rate Risk” disclosure. Accordingly, the Prospectus should more fully disclose that interest rates are at
historic lows and any impact of that on the Registrant. Please discuss the Federal Reserve actions (asset/bond buyback programs)
and other stimulus programs implemented because of the pandemic.

RESPONSE: The Registrant acknowledges
the Staff’s re-issued comment. The Registrant proposes to further enhance the “Epidemic and Pandemic Risk” disclosure
(additions are underlined) in response to this comment. The Registrant respectfully believes that the added disclosure is responsive
to the Staff’s concerns and its inclusion under “Epidemic and Pandemic Risk,” which appears as a sub-section
under “Risk Related to the Economy” in the Prospectus, is appropriate.

Epidemic and Pandemic Risk

An outbreak of respiratory disease caused by a
novel coronavirus was first detected in China in December 2019 and subsequently spread globally (“COVID-19”).
This coronavirus has resulted in closing borders, enhanced health screenings, healthcare service preparation and delivery, quarantines,
cancellations, and disruptions to supply chains, workflow operations and consumer activity, as well as general concern and uncertainty.
The impact of this coronavirus may be short-term or may last for an extended period of time and result in a substantial economic
downturn. Health crises caused by outbreaks, such as the coronavirus outbreak, may exacerbate other pre-existing political, social
and economic risks. The impact of this outbreak, and other epidemics and pandemics that may arise in the future, could negatively
affect the worldwide economy, as well as the economies of individual countries, individual companies (including fund service providers)
and the market in general in significant and unforeseen ways. Any such impact could adversely affect the Fund’s performance.

The United States has responded to the COVID-19
pandemic and resulting economic distress with fiscal and monetary stimulus packages. In late March 2020, the government passed
the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), a stimulus package providing for over $2.2
trillion in resources to small businesses, state and local governments, and individuals that have been adversely impacted by the
COVID-19 pandemic. In addition, in mid-March 2020 the U.S. Federal Reserve (“Fed”) cut interest rates to historically
low levels and has promised unlimited and open-ended quantitative easing, including purchases of corporate and municipal government
bonds. The Fed also enacted various programs to support liquidity operations and funding in the financial markets, including expanding
its reverse repurchase agreement operations, adding $1.5 trillion of liquidity to the banking system; establishing swap lines with
other major central banks to provide dollar funding; establishing a program to support money market funds; easing various bank
capital buffers; providing funding backstops for businesses to provide bridging loans for up to four years; and providing funding
to help credit flow in asset-backed securities markets. The Fed also plans to extend credit to small- and medium-sized businesses.

Questions on this letter or requests for
additional information may be directed to me at (412) 288-4429.

Very truly
yours,

/s/ Mark R. Thompson

Mark R. Thompson

Senior Paralegal
2020-07-15 - CORRESP - Federated Hermes Project & Trade Finance Tender Fund (XPTFX) (CIK 0001677615)
CORRESP
1
filename1.htm

FEDERATED HERMES PROJECT AND TRADE FINANCE
TENDER FUND

4000 Ericsson Drive

Warrendale, Pennsylvania 15086-7561

July 15, 2020

Mr. Mark Cowan

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549-4720

    RE:

        FEDERATED HERMES PROJECT AND TRADE FINANCE TENDER FUND (the “Registrant”)

        1933 Act File No. 333-231065

        1940 Act File No. 811-23174

Dear Mr. Cowan:

The Registrant is filing this correspondence
to respond to comments of the Staff of the Securities and Exchange Commission (the “Staff”) provided on July 7, 2020,
regarding its Post-Effective Amendment No. 1 under the Securities Act of 1933 and Amendment No. 10 under the Investment Company
Act of 1940 to the Form N-2 Registration Statement of the above-referenced Registrant filed on May 13, 2020.

COMMENT 1. Form N-2 Registration

Please confirm what year this filing represents
in the three-year cycle of Form N-2 filings for continuously offered closed-end funds such as the Registrant.

RESPONSE:

The Registrant’s initial registration
statement on Form N-2 was declared effective on December 7, 2016. In connection with the close of the Registrant’s first
three-year cycle, the Registrant filed a new registration statement on Form N-2, which was declared effective on July 26, 2019.
This filing represents the first annual update in the Registrant’s second three-year cycle.

COMMENT 2. Prospectus Cover Page –
Adviser and Sub-Adviser

The assets under management data for the
Adviser and Sub-Adviser is updated as of December 31, 2019. Consider updating the assets under management data to a more recent
date, such as March 31, 2020, the Registrant’s fiscal year end.

RESPONSE:

The Federated Hermes Fund Complex uses
the December 31 calendar year end date to update adviser and sub-adviser background for the registration statements of all Federated
Hermes Funds. This complex-wide practice was determined as a reasonable and consistent approach because of the high number of funds
with varying fiscal years within the Federated Hermes Fund Complex.

COMMENT 3. Prospectus – Risk
Factors – Risk of Investing in Trade Finance Related Securities/Emerging Markets

Should disclosure specifically addressing
investments in China be included in the “Emerging Markets” risk discussion in the summary and statutory Prospectus
risk disclosure?

RESPONSE: Supplementally, the Registrant
notes that it currently has minimal exposure to China. However, given that the Registrant does have some minimal level of
Chinese exposure, the Registrant will add the following “Greater China Risk” to the Statement of Additional Information:

Greater China Risk.
Although larger and/or more established than many emerging markets, the markets of the Greater China region function in many ways
as emerging markets, and carry the high levels of risks associated with emerging markets. Direct investments in, or indirect exposure
to, the Greater China region may be subject to the risks associated with trading on less-developed trading markets, in addition
to acute political risks such as possible negative repercussions resulting from China's relationship with Taiwan or Hong Kong,
restrictions on monetary repatriation, or other adverse government actions. The attitude of the Chinese government toward growth
and capitalism is uncertain, and the markets of Hong Kong and China could be hurt significantly by any government interference
or any material change in government policy. For example, the Chinese government may restrict investment in companies or industries
considered important to national interests, or intervene in the financial markets, such as by imposing trading restrictions, or
banning or curtailing short selling. As export-driven economies, the economies of countries in the Greater China region are affected
by developments in the economies of their principal trading partners. A downturn in these economies could slow or eliminate the
growth of the economies of the Greater China region and adversely impact the Fund's investments.

COMMENT 4. Prospectus – Risk
Factors – Interest Rate Risk

Please update “Interest Rate Risk” to discuss
current historically low interest rates and the impact on the portfolio.

RESPONSE: In response to the Staff’s
comment, the Registrant reviewed the current disclosure and determined that the Interest Rate Risk as drafted appropriately addresses
the risks inherent in investments subject to interest rate fluctuation. Moreover, under “Issuer Credit Risk,” the Registrant
discloses that “[f]ixed-income securities generally compensate for greater credit risk by paying interest at a higher rate.
The difference between the yield of a security and the yield of a U.S. Treasury security or other appropriate benchmark with a
comparable maturity (the “spread”) measures the additional interest paid for risk. Spreads may increase generally in
response to adverse economic or market conditions.” Current market conditions are further discussed under “Epidemic
and Pandemic Risk.” Accordingly, the Registrant respectfully declines to make any changes in response to this comment.

COMMENT 5. Statement of Additional
Information (SAI) – Investment Risks – LIBOR Risk

Please explain why “LIBOR Risk”
is disclosed in the SAI instead of the Prospectus.

RESPONSE:

The Registrant believes that LIBOR Risk
is currently a non-principal risk factor for the Fund and that its placement in the SAI is appropriate in disclosing the transition
away from LIBOR following the benchmark’s discontinuance sometime after 2021. As stated in the LIBOR Risk factor, before
the end of 2021, it is expected that market participants will transition to the use of different reference or benchmark rates.
However, there is currently no definitive information regarding the future utilization of LIBOR or of any particular replacement
rate. Regulators have suggested alternative reference rates, but global consensus is lacking and the process for amending existing
contracts or instruments to transition away from LIBOR remains unclear.

While it is expected that market participants
will amend financial instruments referencing LIBOR to include fallback provisions and other measures that contemplate the discontinuation
of LIBOR or other similar market disruption events, neither the effect of the transition process nor the viability of such measures
is known.

As more information becomes known, the
Registrant will re-assess its disclosure to determine if revisions are necessary including placement in the Prospectus as a principal
risk factor.

COMMENT 6. Prospectus or Statement
of Additional Information - General

Does the Registrant invest in any covenant-lite
loans that would require risk disclosure? If so, please add securities and risk disclosures. If such investments are principal
investments, please place the disclosure in the Prospectus securities and risks sections and consider adding a statement to the
investment strategy.

RESPONSE: Supplementally, the Registrant
notes that it generally does not invest in covenant-lite loans. However, given the potential for subjectivity regarding what constitutes
a covenant-lite loan, the Registrant will add the following “Covenant-Lite Risk” to the SAI:

Covenant-Lite Loans.
The Fund may invest in loans that may be “covenant lite.” This term typically refers to loans that lack, or contain
fewer or contingent, financial maintenance covenants or other provisions intended to provide certain financial protections in favor
of lenders as compared to other types of loans. Financial maintenance covenants generally require a borrower to satisfy certain
financial metrics at regular intervals over the life of the loan. Loans that include financial maintenance covenants will typically
require the borrower to provide a calculation of its financial maintenance covenants and other related financial information on
a periodic basis, which permits the lender to monitor the borrower’s financial performance over time. The failure to satisfy
a financial maintenance covenant as of any required testing period will result in a default and permit the lender, in certain circumstances,
to exercise its rights and remedies against the borrower. Additionally, a lender may determine, based on a borrower’s financial
maintenance covenant calculations, that a borrower is experiencing financial distress or decline, which typically permits the lender
to engage in negotiations with the borrower or take other actions in order to mitigate losses.

Covenant-lite loans carry
greater risks than loans with financial maintenance covenants because the borrower will generally have more flexibility with respect
to its activities, and the Fund or lender may receive less frequent or less detailed financial reporting from the borrower and
may experience greater delays and difficulties in enforcing its rights if the borrower’s financial performance declines,
which may result in losses to the Fund. For example, if a default occurs, covenant-lite loans may exhibit diminished recovery values
because the Fund or lender may not have had the opportunity to negotiate with the borrower prior to the default and otherwise may
have limited financial information or a limited ability to intervene or obtain concessions from a borrower prior to default. Ultimately,
these loans provide fewer protections in favor of the Fund, including with respect to the possibility of default, as well as a
more limited ability to declare a default. These risks are particularly acute during a downturn in the credit cycle.

COMMENT 7. Statement of Additional
Information – Management of the Fund

Please confirm that the information required
by Item 18 of Form N-2, particularly the trustees and officers table, is current.

RESPONSE:

The Registrant confirms that all applicable
trustee and officer table information required by Item 18 of Form N-2 is and will be current as of the filing date of the registration
statement.

COMMENT 8. Registration Statement -
General

Please verify that all documents incorporated
by reference are hyperlinked.

RESPONSE:

The Registrant confirms that all applicable
documents incorporated by reference are and will be hyperlinked in the registration statement.

Questions on this letter or requests for
additional information may be directed to me at (412) 288-4429.

Very truly
yours,

/s/ Mark R. Thompson

Mark R. Thompson

Senior Paralegal