Montgomery, McCracken, Walker & Rhoads, llp
attorneys at law
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Don E. Felice
Admitted in Pennsylvania, New Jersey
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123 South Broad Street
Avenue of the Arts
Philadelphia, PA 19109-1029
215-772-1500
Fax 215-772-7620
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Direct Dial
(215) 772-7385
dfelice@mmwr.com
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Re:
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Rochdale Investment Trust, Rochdale Alternative Total Return Fund, LLC, Rochdale Core Alternative Strategies Fund, LLC, Rochdale Core Alternative Strategies Fund TEI, LLC, Rochdale Core Alternative Strategies Master Fund, LLC, Rochdale Structured Claims Fixed Income Fund, LLC (collectively, “Registrants”)
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1.
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You requested that that anticipated date of the mailing of the proxy statement and that fact that each share of each fund is entitled to one vote be set forth on the first page of the proxy statement.
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Response: Registrants will amend the disclosure as requested.
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2.
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Under the “Committees of the Board” disclosure in Proposal 1, you requested certain additional disclosure regarding the activities of the Funds’ Audit Committees.
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Response: Registrants will amend the disclosure as requested.
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3.
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Also under the “Committees of the Board” disclosure in Proposal 1, you requested certain additional disclosure regarding the Funds’ Nominating Committees.
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Response: Registrants will amend the disclosure as requested.
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4.
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In Proposal 2, you suggested that additional disclosure be added more explicitly linking the decision to include international bond exposure in the Fixed Income Opportunities Portfolio’s investment portfolio and the decision to recommend the hiring of GML as a sub-advisor.
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Response: Registrants will amend the disclosure as suggested.
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5.
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Also in Proposal 2, you requested that Registrant include disclosure about possible additional risks that the Fixed Income Opportunities Portfolio may be subject to with the addition of the new sub-advisor’s investment style.
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Response: Registrants will amend the disclosure as suggested.
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6.
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In section setting forth information on the Fixed Income Opportunities Portfolio’s management organizations, you requested additional disclosure regarding the Portfolio’s existing sub-advisers.
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Response: Registrants will amend the disclosure as suggested.
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7.
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In the disclosure regarding brokerage commission paid under the heading “Other Matters,” you requested additional disclosure regarding the affiliated brokerage paid by the Dividend & Income Portfolio.
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Response: Registrants will amend the disclosure as suggested.
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