0001145549-20-025241.txt : 20200514 0001145549-20-025241.hdr.sgml : 20200514 20200514133548 ACCESSION NUMBER: 0001145549-20-025241 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 2 CONFORMED PERIOD OF REPORT: 20200229 FILED AS OF DATE: 20200514 DATE AS OF CHANGE: 20200514 EFFECTIVENESS DATE: 20200514 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Destra Multi-Alternative Fund CENTRAL INDEX KEY: 0001523289 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: N-CEN SEC ACT: 1940 Act SEC FILE NUMBER: 811-22572 FILM NUMBER: 20876781 BUSINESS ADDRESS: STREET 1: 80 ARKAY DRIVE CITY: HAUPPAUGE STATE: NY ZIP: 11788 BUSINESS PHONE: 631-470-2600 MAIL ADDRESS: STREET 1: 80 ARKAY DRIVE CITY: HAUPPAUGE STATE: NY ZIP: 11788 FORMER COMPANY: FORMER CONFORMED NAME: Multi-Strategy Growth & Income Fund DATE OF NAME CHANGE: 20110614 N-CEN 1 primary_doc.xml X0201 N-CEN LIVE 0001523289 XXXXXXXX true false false N-2 DESTRA MULTI-ALTERNATIVE FUND 811-22572 0001523289 549300SP0KUS5HR5P569 444 WEST LAKE STREET SUITE 1700 CHICAGO 60606 US-IL US 3128436161 UMB FUND SERVICES, INC 235 W GALENA STREET MILWAUKEE 53212 4142992000 FUND ADMINISTRATOR, FUND ACCOUNTANT AND TRANSFER AGENT UMB BANK, N.A. 1010 GRAND BLVD KANSAS CITY 64106 8168601142 CUSTODIAN DESTRA CAPITAL ADVISORS LLC 444 WEST LAKE STREET SUITE 1700 CHICAGO 60606 3128436161 INVESTMENT MANAGER PINHOOK CAPITAL, LLC 13520 EVENING CREEK DRIVE NORTH SUITE 300 SAN DIEGO 92128 8006441150 SUB-ADVISER FAEGRE DRINKER BIDDLE & REATH LLP ONE LOGAN SQUARE SUITE 2000 PHILADELPHIA 19103 2159882700 LEGAL COUNSEL N N N-2 Y JOHN S EMRICH 006852043 N MICHAEL S ERICKSON N/A N JEFFREY S MURPHY 002536325 N NICHOLAS DALMASO 002246955 Y JANE HONG SHISSLER N/A 444 WEST LAKE STREET SUITE 1700 CHICAGO 60606 XXXXXX N N N N N N N DESTRA CAPITAL INVESTMENTS LLC 8-68006 000148299 N/A Y N COHEN AND COMPANY, LTD 00925 N/A Y N N N N DESTRA MULTI-ALTERNATIVE FUND 549300SP0KUS5HR5P569 N 0 0 0 Interval Fund Y N N N N/A N/A N/A Rule 17e-1 (17 CFR 270.17e-1) Rule 22d-1 (17 CFR 270.22d-1) Rule 32a-4 (17 CFR 270.32a-4) Y Y Y N DESTRA CAPITAL ADVISORS LLC 801-71604 000148574 N/A N PINHOOK CAPITAL, LLC 801-72595 000158509 N/A N N UMB FUND SERVICES, INC 84-5792 N/A N N Y INTERCONTINENTAL EXCHANGE, INC. 5493000F4ZO33MV32P92 N N UMB BANK, N.A. VNOO6EITDJ2YUEBMSZ83 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N DESTRA CAPITAL INVESTMENTS LLC 8-68006 SEC FILE NUMBER Y N N UMB FUND SERVICES, INC. 84-5792 SEC FILE NUMBER N N Y INTERACTIVE BROKERS LLC 8-47257 000036418 50OBSE5T5521O6SMZR28 10086.000000000000 LUCIA SECURITIES, LLC 8-47643 000037179 N/A 2794.000000000000 12880.000000000000 0.000000000000 N 143641005.000000000000 Common stock CLASS I SHARES Common stock CLASS A SHARES Common stock CLASS T SHARES Common stock CLASS C SHARES N N Common stock N N N 1.350000000000 2.570000000000 13.250000000000 13.250000000000 true INTERNAL CONTROL RPT 2 internalcontrol.htm INTERNAL CONTROL LETTER

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Shareholders and Board of Trustees of

Destra Multi-Alternative Fund

In planning and performing our audit of the financial statements of Destra Multi-Alternative Fund (the “Fund”) as of and for the year ended February 29, 2020, 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.

The 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 fund’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 (GAAP). A fund’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 fund; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the fund are being made only in accordance with authorizations of management and Trustees of the fund; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a fund’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 combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the Fund’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 February 29, 2020.

This report is intended solely for the information and use of management and the Board of Trustees of the 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/ COHEN & COMPANY, LTD.

COHEN & COMPANY, LTD.

Chicago, Illinois

May 5, 2020