Report of Independent Registered Public Accounting Firm
To the Shareholders and Board of Trustees abrdn Income Credit Strategies Fund:
In planning and performing our audit of the financial statements of abrdn Income Credit Strategies Fund (formerly, Aberdeen Income Credit Strategies Fund) (the Fund) as of and for the year ended October 31, 2022, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered the Fund's internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Fund's internal control over financial reporting. Accordingly, we express no such opinion.
Management of the Fund is responsible for establishing and maintaining effective internal control over financial reporting. In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls. A company's internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company's internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the company's assets that could have a material effect on the financial statements.
Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the company’s annual or interim financial statements will not be prevented or detected on a timely basis.
Our consideration of the Fund's internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the Public Company Accounting Oversight Board (United States). However, we noted no deficiencies in the Fund's internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness as defined above as of October 31, 2022.
This report is intended solely for the information and use of the management and the Board of Trustees of abrdn Income Credit Strategies Fund and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.
/s/ KPMG LLP
Philadelphia, Pennsylvania
December 29, 2022
2
Item G.1.b.i. material amendments to organizational documents.
(1)
AMENDMENT TO THE
AMENDED AND RESTATED
AGREEMENT AND DECLARATION OF TRUST
OF
ABERDEEN INCOME CREDIT STRATEGIES FUND
This Amendment dated June 10, 2022 (the “Amendment”) to the AMENDED AND RESTATED AGREEMENT AND DECLARATION OF TRUST, as amended and restated on December 9, 2010, of the Aberdeen Income Credit Strategies Fund (the “Trust”) is made by the Trustees hereunder.
WITNESSETH THAT:
WHEREAS, the Trustees desire to amend Section 1.01 of the Amended
and Restated Declaration of Trust, dated December 9, 2010, in its entirety
in order to reflect a change in the name of the Trust as follows, effective June 30, 2022:
Current Name New Name
Aberdeen Income Credit Strategies Fund abrdn Income Credit Strategies Fund
NOW THEREFORE BE IT, that Section 1.01 of the Amended and Restated Declaration of Trust shall be restated in its entirety as follows, effective June 30, 2022:
Section 1.01. Name. The name of the Trust shall be “abrdn Income Credit Strategies Fund” and the Trustees shall conduct the business of the Trust under the name or any other name or names as they may from time to time determine. Any name change shall become effective upon the execution by a Majority of the Trustees of an instrument setting forth the new name and the effectiveness of a certificate of amendment filed pursuant to Section 3810(b) of the Delaware Statutory Trust Act. Any such instrument shall not require the approval of the Shareholders, but shall have the status of an amendment to this Declaration.
(remainder of page intentionally blank)
IN WITNESS WHEREOF, the undersigned Trustees have set their hand and seal, for themselves and their assigns, unto this Amendment to the Amended and Restated Declaration of Trust of Aberdeen Income Credit Strategies Fund, all as of the day and year first above written. This Amendment to the Agreement and Declaration of Trust may be executed in any number of counterparts, each of which shall be deemed an original, but all such counterparts together shall constitute one and the same instrument.
/s/ John Sievwright
John Sievwright
/s/ P. Gerald Malone
P. Gerald Malone
/s/ Randolph Takian
Randolph Takian
/s/ Nancy Yao Maasbach
Nancy Yao Maasbach
/s/ Stephen Bird
Stephen Bird
(2)
STATE OF DELAWARE CERTIFICATE OF AMENDMENT TO CERTIFICATE OF TRUST
Pursuant to Title 12, Section 3810(b) of the Delaware Statutory Trust Act, the undersigned Trust executed the following Certificate of Amendment:
1. Name of Statutory Trust:
Aberdeen Income Credit Strategies Fund
2. The Certificate of Amendment to the Certificate of Trust is hereby amended as follows:
Name of Statutory Trust:
abrdn Income Credit Strategies Fund
[set forth amendment(s)]
3. (Please complete with either upon filing or it may be a future effective date that is within 90 days of the file date) This Certificate of Amendments shall be
effective
June 30, 2022 .
IN WITNESS WHEREOF, the undersigned have executed this Certificate on
the 10th
day of
June
, 2022
A.D.
By: /s/ John Sievwright
Trustee Name: John Sievwright
Type or Print
Item G.1.b.iv. Information called for by Item 405 of Regulation S-K:
Delinquent Section 16(a) Reports
Section 16(a) of the 1934 Act and Section 30(h) of the 1940 Act, as applied to the Fund, require the Fund's officers and Trustees, certain officers and directors of the investment advisers, affiliates of the investment advisers, and persons who beneficially own more than 10% of the Fund's outstanding securities (collectively, the “Reporting Persons”) to electronically file reports of ownership of the Fund's securities and changes in such ownership with the SEC and the NYSE.
Based solely on the Fund’s review of such forms filed on EDGAR or written representations from Reporting Persons that all reportable transactions were reported, to the knowledge of the Fund, during the fiscal period ended October 31, 2022, the Fund’s Reporting Persons timely filed all reports they were required to file under Section 16(a), except that: (i) Robert Hepp and Andrew Kim each filed a late Form 3 filing following their respective appointments as Vice Presidents of the Fund; and (ii) Grant Hotson and Neil Slater each filed a late Form 3 filing following their respective appointments as directors of the Fund’s investment adviser.