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ROPES & GRAY LLP
PRUDENTIAL TOWER
800 BOYLSTON STREET
BOSTON, MA 02199-3600
WWW.ROPESGRAY.COM |
April 26, 2024 | Adam M. Schlichtmann
T +1 617 951 7114
F +1 617 235 7346
adam.schlichtmann@ropesgray.com |
VIA EDGAR CORRESPONDENCE
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Ken Ellington
Re: | Sarbanes-Oxley Review of PIMCO Closed-End Funds |
Dear Mr. Ellington:
Thank you for your oral comments provided on February 1, 2024, regarding the staff of the Securities and Exchange Commission’s (the “SEC”) review, pursuant to the Sarbanes-Oxley Act of 2002, of the financial statements contained in the reports to shareholders, as well as related disclosures in the prospectuses and other filings of the PIMCO closed-end funds listed on Appendix A, attached hereto (each a “Fund,” and collectively, the “Funds”), for the fiscal year ended June 30, 2023 (the “2023 Annual Report”). Your comments are summarized below to the best of our understanding, followed by the Funds’ responses. Unless otherwise noted, the responses relate to all Funds.
* * *
1. | Comment: PCM Fund, Inc. (“PCM”) appears to hold a number of securities that are identified as in default on the schedule of investments. The majority of these securities are not marked as non-income producing. Please explain. |
Response: Many of the positions identified as “defaulted” in the Fund’s Schedule of Investments produced income during the reporting period.
2. | Comment: It appears that PIMCO Corporate & Income Opportunity Fund, PIMCO Corporate & Income Strategy Fund, PIMCO Flexible Emerging Markets Income Fund, PIMCO High Income Fund, PIMCO Income Strategy Fund and PIMCO Income Strategy Fund II each have significant investments in bank loans. If the Funds received consent fees, upfront origination fees, and/or amendment fee income from such loans (which is different from interest income), please ensure that such income amounts are disclosed appropriately in the notes to the financial statements, along with the policy to recognize such income in accordance with applicable U.S. GAAP. |
- 2 - | April 26, 2024 |
Response: The Fund will add the requested income amounts, as appropriate, in future filings on Form N-CSR when such income amounts are material.
3. | Comment: The disclosure above the “Effects of Leverage” table in the 2023 Annual Report for PCM, PIMCO Global StocksPLUS® & Income Fund, PIMCO Strategic Income Fund, Inc., PIMCO Access Income Fund, PIMCO Dynamic Income Fund and PIMCO Dynamic Income Opportunities Fund states that it is based on market conditions as of June 30, 2019. Please confirm if this disclosure is accurate and ensure that this information is updated to a more recent date going forward. |
Response: The “Effects of Leverage” table in the 2023 Annual Report related to the fiscal year ended June 30, 2023 and the reference to “June 30, 2019” was a typographical error (i.e., the reference should have been to “June 30, 2023”). The correct “market conditions as of” date will be referenced in future “Effects of Leverage” tables.
* * *
We hope the foregoing responses adequately address the SEC staff’s comments. Should you have any further questions or comments, please do not hesitate to contact me at (617) 951-7114.
Sincerely,
/s/ Adam M. Schlichtmann
Adam M. Schlichtmann
cc: | Ryan Leshaw, Pacific Investment Management Company LLC |
Timothy Bekkers, Pacific Investment Management Company LLC
Jaime Dinan, Pacific Investment Management Company LLC
Appendix A
File No. |
Registrant/Series Name | |
811-21238 |
PCM Fund, Inc. | |
811-21734 |
PIMCO Global StocksPLUS® & Income Fund | |
811-08216 |
PIMCO Strategic Income Fund, Inc. | |
811-23749 |
PIMCO Access Income Fund | |
811-22673 |
PIMCO Dynamic Income Fund | |
811-23505 |
PIMCO Dynamic Income Opportunities Fund | |
811-23390 |
PIMCO Dynamic Income Strategy Fund | |
811-21238 |
PIMCO Corporate & Income Opportunity Fund | |
811-10555 |
PIMCO Corporate & Income Strategy Fund | |
811-21311 |
PIMCO High Income Fund | |
811-21374 |
PIMCO Income Strategy Fund | |
811-21601 |
PIMCO Income Strategy Fund II | |
811-23211 |
PIMCO Flexible Credit Income Fund | |
811-23648 |
PIMCO Flexible Emerging Markets Income Fund |