The Fund believes that during fiscal year
ended December 31, 2019, its Reporting
Persons complied with all Section 16(a) filing
requirements, except that each of the initial
Form 3's of Eric Stampfel, Eban Cucinotta,
Christopher Morser, Gary Chan, and Robert
Rafter, portfolio managers of the Fund, were
filed untimely following each individual's
respective appointment as a portfolio manager
of the Fund.  All of the referenced filings have
now been made.