0001752724-19-035764.txt : 20190514 0001752724-19-035764.hdr.sgml : 20190514 20190514162406 ACCESSION NUMBER: 0001752724-19-035764 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 2 CONFORMED PERIOD OF REPORT: 20190228 FILED AS OF DATE: 20190514 DATE AS OF CHANGE: 20190514 EFFECTIVENESS DATE: 20190514 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: 19823066 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 811-22572 N-2 Destra Multi-Alternative Fund 811-22572 0001523289 549300SP0KUS5HR5P569 444 West Lake Street Suite 1700 Chicago 60606 US-IL US 877-855-3434 Gemini Fund Services LLC 80 Arkay Drive, Suite 110 Hauppauge 11788 631-470-2600 Fund Accounting and Transfer Agent Records Y N N-2 Y John S. Emrich, CFA 006852043 N Nicholas Dalmaso 002246955 N Jeffery S. Murphy 002536325 N Michael S. Erickson N/A N Destra Capital Advisors LLC N/A 444 West Lake St. Ste. 1700 Chicago 60606 XXXXXX Y Northern Lights Compliance Services, LLC N/A 17605 Wright Street Omaha 68130 XXXXXX Y N N N N N Northern Lights Distributors, LLC 8-065857 000126159 N/A N Destra Capital Investments LLC 008-68006 000148299 N/A Y Y Deloitte & Touche LLP 34 N/A N N N N N N Destra Multi-Alternative Fund 549300SP0KUS5HR5P569 Y 0 0 0 Interval Fund Y N N N N/A N/A N/A Rule 32a-4 (17 CFR 270.32a-4) Rule 17e-1 (17 CFR 270.17e-1) Y Y Y N Destra Capital Advisors LLC 028-15699 000148299 N/A N LCM Investment Management, LLC 801-72595 000158509 N/A 2018-11-30 Pinhook Capital, LLC 801-72595 000158509 N/A N Gemini Fund Services, LLC 84-06083 N/A N N N ICE Data Services N/A N N UMB Bank VNOO6EITDJ2YUEBMSZ83 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N DESTRA CAPITAL INVESTMENTS LLC 8-68006 SEC number N N Gemini Fund Services, LLC 84-06083 Filing Number N N Y Gemini Fund Services, LLC N/A N N N Destra Capital Investments LLC 008-68006 000148299 N/A 0.00000000 Lucia Securities 8-47643 000037179 N/A 15884.01000000 15884.01000000 JPMorgan Chase 8-35008 000000079 N/A 2992108.50000000 Credit Suisse 8-0137170 000106012 N/A 2450758.72000000 5442867.22000000 N 204293550.58000000 Common stock DESTRA MULTI-ALTERNATIVE FUND CLASS A Common stock DESTRA MULTI-ALTERNATIVE FUND CLASS C Common stock DESTRA MULTI-ALTERNATIVE FUND CLASS I Common stock DESTRA MULTI-ALTERNATIVE CLASS L N N N N N N 0.0135 0.01950000 N/A 13.60000000 true INTERNAL CONTROL RPT 2 Destra_ncenLetter.txt DESTRA_IC_LETTER REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Shareholders and Board of Trustees of The Destra Multi-Alternative Fund: In planning and performing our audit of the financial statements of Destra Multi-Alternative Fund (formerly known as Multi-Strategy Growth & Income Fund) (the "Fund") as of and for the year ended February 28, 2019, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Funds 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 consolidated 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 Funds 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 funds internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of consolidated financial statements for external purposes in accordance with generally accepted accounting principles. A funds 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 consolidated financial statements in accordance with generally accepted accounting principles, 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 funds assets that could have a material effect on the consolidated 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 funds annual or interim consolidated financial statements will not be prevented or detected on a timely basis. Our consideration of the Funds 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 PCAOB. However, we noted no deficiencies in the Funds internal control over financial reporting and its operation, including controls for safeguarding securities, that we consider to be a material weakness, as defined above, as of February 28, 2019. 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. Deloitte & Touche LLP Costa Mesa, California April 26, 2019