0001305197-14-000004.txt : 20141030 0001305197-14-000004.hdr.sgml : 20141030 20140916114818 ACCESSION NUMBER: 0001305197-14-000004 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20140916 FILER: COMPANY DATA: COMPANY CONFORMED NAME: MANAGED DURATION INVESTMENT GRADE MUNICIPAL FUND CENTRAL INDEX KEY: 0001235511 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 227 WEST MONROE STREET CITY: CHICAGO STATE: IL ZIP: 60606 BUSINESS PHONE: 312-827-0100 MAIL ADDRESS: STREET 1: 227 WEST MONROE STREET CITY: CHICAGO STATE: IL ZIP: 60606 FORMER COMPANY: FORMER CONFORMED NAME: MBIA CAPITAL/CLAYMORE MAN DUR INV GRD MUNI FUND DATE OF NAME CHANGE: 20090630 FORMER COMPANY: FORMER CONFORMED NAME: MBIA CAPITAL CLAYMORE MAN DUR INV GRD MUNI FUND DATE OF NAME CHANGE: 20030814 FORMER COMPANY: FORMER CONFORMED NAME: MBIA CAPITAL CLAYMORE MANAGED DURATION NATIONAL MUNICIPAL TR DATE OF NAME CHANGE: 20030523 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GUGGENHEIM ENHANCED EQUITY STRATEGY FUND CENTRAL INDEX KEY: 0001267890 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 2455 CORPORATE WEST DRIVE CITY: LISLE STATE: IL ZIP: 60532 BUSINESS PHONE: 6305053700 MAIL ADDRESS: STREET 1: 2455 CORPORATE WEST DRIVE CITY: LISLE STATE: IL ZIP: 60532 FORMER COMPANY: FORMER CONFORMED NAME: CLAYMORE DIVIDEND & INCOME FUND DATE OF NAME CHANGE: 20090626 FORMER COMPANY: FORMER CONFORMED NAME: DREMAN CLAYMORE DIVIDEND & INCOME FUND DATE OF NAME CHANGE: 20031022 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDUCIARY/CLAYMORE MLP OPPORTUNITY FUND CENTRAL INDEX KEY: 0001305197 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 227 WEST MONROE STREET CITY: CHICAGO STATE: IL ZIP: 60606 BUSINESS PHONE: 312-827-0100 MAIL ADDRESS: STREET 1: 227 WEST MONROE STREET CITY: CHICAGO STATE: IL ZIP: 60606 FORMER COMPANY: FORMER CONFORMED NAME: Fiduciary/Claymore MLP Opportunity Fund DATE OF NAME CHANGE: 20041005 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GUGGENHEIM STRATEGIC OPPORTUNITIES FUND CENTRAL INDEX KEY: 0001380936 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 227 WEST MONROE STREET CITY: CHICAGO STATE: IL ZIP: 60606 BUSINESS PHONE: 312-827-0100 MAIL ADDRESS: STREET 1: 227 WEST MONROE STREET CITY: CHICAGO STATE: IL ZIP: 60606 FORMER COMPANY: FORMER CONFORMED NAME: CLAYMORE/GUGGENHEIM STRATEGIC OPPORTUNITIES FUND DATE OF NAME CHANGE: 20090630 FORMER COMPANY: FORMER CONFORMED NAME: Claymore/Guggenheim Strategic Opportunities Fund DATE OF NAME CHANGE: 20070605 FORMER COMPANY: FORMER CONFORMED NAME: Claymore Strategic Opportunities Fund DATE OF NAME CHANGE: 20061113 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Guggenheim Build America Bonds Managed Duration Trust CENTRAL INDEX KEY: 0001495825 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 227 WEST MONROE STREET CITY: CHICAGO STATE: IL ZIP: 60606 BUSINESS PHONE: 312-827-0100 MAIL ADDRESS: STREET 1: 227 WEST MONROE STREET CITY: CHICAGO STATE: IL ZIP: 60606 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Guggenheim Equal Weight Enhanced Equity Income Fund CENTRAL INDEX KEY: 0001526104 IRS NUMBER: 000000000 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 227 WEST MONROE STREET CITY: CHICAGO STATE: IL ZIP: 60606 BUSINESS PHONE: 312-827-0100 MAIL ADDRESS: STREET 1: 227 WEST MONROE STREET CITY: CHICAGO STATE: IL ZIP: 60606 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Guggenheim Enhanced Equity Income Fund (f/k/a Old Mutual/Claymore Long-Short Fund) CENTRAL INDEX KEY: 0001310709 IRS NUMBER: 436922646 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: C/O GUGGENHEIM FUNDS STREET 2: 227 WEST MONROE STREET CITY: CHICAGO STATE: IL ZIP: 6606 BUSINESS PHONE: 312-827-0100 MAIL ADDRESS: STREET 1: C/O GUGGENHEIM FUNDS STREET 2: 227 WEST MONROE STREET CITY: CHICAGO STATE: IL ZIP: 6606 FORMER COMPANY: FORMER CONFORMED NAME: Old Mutual/Claymore Long-Short Fund (f.k.a. Analytic Covered Call Plus Fund) DATE OF NAME CHANGE: 20050627 FORMER COMPANY: FORMER CONFORMED NAME: Old Mutual/Claymore Long-Short Premium Fund (f.k.a. Analytic Covered Call Plus Fund) DATE OF NAME CHANGE: 20050411 FORMER COMPANY: FORMER CONFORMED NAME: Old Mutual/Claymore Long-Short Premium Fund (f.k.a-Analytic Covered Call Plus Fund) DATE OF NAME CHANGE: 20050406 CORRESP 1 filename1.htm CEFsSECS-OxReviewResponseLetterSeptember2014v3 (1)


[Letterhead of Guggenheim]
September 16, 2014
Chad D. Eskildsen
Division of Investment Management, Disclosure
Review and Accounting
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549

RE:
Fiduciary/Claymore MLP Opportunity Fund
(File No. 811-21652)
Guggenheim Build America Bonds Managed Duration Trust
(File No. 811-22437)
Guggenheim Enhanced Equity Income Fund
(File No. 811-21681)
Guggenheim Enhanced Equity Strategy Fund
(File No. 811-21455)
Guggenheim Equal Weight Enhanced Equity Income Fund
(File No. 811-22584)
Guggenheim Strategic Opportunities Fund
(File No. 811-21982)
Managed Duration Investment Grade Municipal Fund
(File No. 811-21359) (collectively, the “Funds”)    
Dear Mr. Eskildsen:
Thank you for your telephonic comments, received August 12, 2014, regarding the Sarbanes-Oxley financial statement reviews of the Funds listed above (the “Financial Statements”). We have considered your comments and, on behalf of the Funds, responses to those comments are set forth below.

Comment 1
With regards to the table disclosed on the Fund Summary page titled “Distributions to Shareholders & Annualized Distribution Rate”, please note whether the distributions may be characterized as return of capital. If a distribution includes return of capital, please provide a percentage calculation of the return of capital portion of the distribution. Throughout the report, please use the term “dividend” only in situations where a distribution does not include return of capital.


Securities and Exchange Commission
September 16, 2014
Page 2



Response 1
The Funds will revise language on the Fund Summary page to provide for an estimate of the percentage of return of capital of the respective distributions, as applicable. Such revisions will be reflected in Financial Statements going forward. The Funds’ new language is provided below:

All or a portion of the above distributions may be characterized as a return of capital. For the year ended [December 31, 2013] approximately [ ]% of the distributions were characterized as return of capital. For the current year, as of [June 30, 2014], [ ]% of the distributions were estimated to be characterized as return of capital. The final determination of the tax character of the distributions paid by the Fund in 2014 will be reported to shareholders in January 2015.

The Funds will also discontinue using the term “dividend” when referring to distributions that may include return of capital.

Comment 2
When providing multiple “Ratios to Average Net Assets,” please provide the ratio required by the Investment Company Act of 1940, as amended, as the most prominently displayed ratio within the Financial Highlights.

Response 2
The Funds have revised disclosure as requested effective with the May 31, 2014 financial statements. Supplemental ratios have been moved to a footnote within the Financial Highlights section.


* * *
Should you have any additional comments or concerns, please do not hesitate to contact me at (312) 357-0394 or John Sullivan at (312) 357-0380.
Sincerely,

/s/ Mark E. Mathiasen

Mark E. Mathiasen
Secretary of the Funds