0001752724-20-117188.txt : 20200611 0001752724-20-117188.hdr.sgml : 20200611 20200611132631 ACCESSION NUMBER: 0001752724-20-117188 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 4 CONFORMED PERIOD OF REPORT: 20200331 FILED AS OF DATE: 20200611 DATE AS OF CHANGE: 20200611 EFFECTIVENESS DATE: 20200611 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Principal Diversified Select Real Asset Fund CENTRAL INDEX KEY: 0001756404 IRS NUMBER: 832104764 STATE OF INCORPORATION: DE FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: N-CEN SEC ACT: 1940 Act SEC FILE NUMBER: 811-23403 FILM NUMBER: 20956789 BUSINESS ADDRESS: STREET 1: 711 HIGH ST. CITY: DES MOINES STATE: IA ZIP: 50392 BUSINESS PHONE: 5152359328 MAIL ADDRESS: STREET 1: 711 HIGH ST. CITY: DES MOINES STATE: IA ZIP: 50392 N-CEN 1 primary_doc.xml X0201 N-CEN LIVE 0001756404 XXXXXXXX 811-23403 true N-2 Principal Diversified Select Real Asset Fund 811-23403 0001756404 549300HSJTLJOEDEF407 801 Grand Ave Des Moines 50309 US-IA US 515-248-0156 Principal Global Investors, LLC 801 Grand Avenue Des Moines 50309 515-248-0156 Governance, compliance, accounting, administrative and investment oversight records Y N N-2 Y Timothy M. Dunbar N/A Y Patrick G. Halter N/A Y Elizabeth A. Nickels N/A N Mary M. VanDeWeghe N/A N Elizabeth Ballatine N/A N Tao Huang N/A N Leroy T. Barnes, Jr N/A N Craig Damos N/A N Fritz Hirsch N/A N Karen McMillan N/A N Mark A. Grimmett N/A N Teri R. Root 004458076 801 Grand Avenue Des Moines 50309 XXXXXX N N N N N Principal Funds Distributor, Inc. 8-50200 000043261 N/A Y N Ernst & Young LLP 42 N/A N Y N N N N Principal Diversified Select Real Asset Fund 549300HSJTLJOEDEF407 Y 0 0 0 Interval Fund N N N N N/A N/A N/A Rule 32a-4 (17 CFR 270.32a-4) Rule 22d-1 (17 CFR 270.22d-1) Y Y N N Principal Global Investors, LLC 801-55959 000109002 549300BABIOZPCNHMB89 N DDJ Capital Management LLC 801-55001 000108468 549300ZLX14T3RGX6L55 N N Principal Real Estate Investors LLC 801-55618 000109008 549300MQOXJ8V8FMMS34 Y N ClearBridge RARE Infrastructure (North America) PTY Limited 801-70506 000151223 549300JIEINNUZB0YC91 N AU N KLS Diversified Asset Management 801-72408 000155837 549300GNP41K7WVJDT93 N N Tortoise Capital Advisors LLC 801-61622 000123711 2549002CGOZK5RQVXG26 N N Tortoise Credit Strategies 801-101546 000277046 5493000LXFOW2QLPNK31 2020-01-01 Principal Shareholder Services, Inc. 084-05657 N/A Y N DST Asset Manager Solutions, Inc. 084-00896 N/A N Y N IHS Markit 549300HLPTRASHS0E726 N Bloomberg Finance L.P 5493001KJTIIGC8Y1R12 N ICE Data Pricing & Reference Data, LLC 5493000F4ZO33MV32P92 N JPM PricingDirect 549300WIC0TOJ7N7GD54 N Duff & Phelps N/A N N HSBC BANK AUSTRALIA LIMITED DY9DBNI4W8J63Z298033 AU N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) SANTANDER SECURITIES SERVICES S.A. 95980020140005900000 ES N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) DBS BANK LTD, SINGAPORE ATUEL7OJR5057F2PV266 SG N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) HSBC SHANGHAI 2CZOJRADNJXBLT55G526 CN N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) DEUTSCHE BANK, ISTANBUL 789000N5SE3LWDK7OI11 TR N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) THE BANK OF NEW YORK MELLON N/A FI N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) ESES FRANCE BEARER N/A FR N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) THE BANK OF NEW YORK MELLON N/A PT N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) THE BANK OF NEW YORK MELLON N/A FR N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) DEUTSCHE BANK AG, MANILA BRANCH N/A PH N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) CREDIT SUISSE (SWITZERLAND) LTD 549300CWR0W0BCS9Q144 CH N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) THE BANK OF NEW YORK MELLON N/A GR N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) CITIBANAMEX, MEXICO CITY 549300DHL7BK624NK881 MX N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) SKANDINAVISKA ENSKILDA BANKEN AB, OSLO BRANCH N/A NO N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) STANDARD BANK OF SOUTH AFRICA, JOHANNESBURG QFC8ZCW3Q5PRXU1XTM60 ZA N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) THE BANK OF NEW YORK MELLON SA/NV N/A IT N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) HONGKONG AND SHANGHAI BANKING CORPORATION, HONG KONG 2HI3YI5320L3RW6NJ957 CN N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) HONGKONG AND SHANGHAI BANKING CORPORATION, HONG KONG 2HI3YI5320L3RW6NJ957 HK N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) THE BANK OF NEW YORK MELLON N/A CN N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) DEUTSCHE BANK AG, JAKARTA N/A ID N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) Bank of New York Mellon HPFHU0OQ28E4N0NFVK49 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) DEUTSCHE BANK (MALAYSIA) BERHAD 529900DLWFR8HK7DR278 MY N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) BANCO DE CHILE 8B4EZFY8IHJC44TT2K84 CL N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) BANK HAPOALIM B.M. B6ARUI4946ST4S7WOU88 IL N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) THE BANK OF NEW YORK MELLON 549300KP56LL8NKKFL47 GB N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) HSBC SHENZHEN 213800H3TEBTFHD5JR69 CN N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) SKANDINAVISKA ENSKILDA BANKEN, STOCKHOLM F3JS33DEI6XQ4ZBPTN86 SE N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) THE BANK OF NEW YORK MELLON N/A ES N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) HONGKONG AND SHANGAI BANKING CORPORATION, BANGKOK N/A TH N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) THE BANK OF NEW YORK MELLON SA/NV, ASSET SERVICING, NIEDERLASSUNG FRANKFURT AM MAIN N/A DE N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) CITIBANK EUROPE PLC, HUNGARIAN BRANCH OFFICE N/A HU N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) CIBC MELLON TRUST COMPANY 549300IYUUH221WBZ505 CA N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) BNP PARIBAS SECURITIES SERVICES, ATHENS N/A GR N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) HSBC NEW ZEALAND 213800NHDWIZKO5KIH05 NZ N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) EUROCLEAR BELGIUM 21380014SJC1QPK8O356 BE N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) SKANDINAVISKA ENSKILDA BANKEN, HELSINKI BRANCH N/A FI N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) SKANDINAVISKA ENSKILDA BANKEN AB, COPENHAGEN BRANCH N/A DK N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) ESES FRANCE REGISTERED N/A FR N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) NATIONAL BANK OF BELGIUM N/A BE N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) CITIBANK N.A., BRAZILIAN BRANCH 1P0UUG7LC1S92QTNHG39 BR N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) THE BANK OF NEW YORK MELLON HPFHU0OQ28E4N0NFVK49 IE N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) EUROCLEAR BANK, BRUSSELS 549300OZ46BRLZ8Y6F65 BE N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) MUFG BANK, LTD 549300OB5SQ53A8BTO30 JP N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) BANK POLSKA KASA OPIEKI S.A. 5493000LKS7B3UTF7H35 PL N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) CITIBANK EUROPE PLC N/A PT N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) THE BANK OF NEW YORK MELLON SA/NV N/A NL N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) THE BANK OF NEW YORK MELLON N/A AT N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) THE BANK OF NEW YORK MELLON MMYX0N4ZEZ13Z4XCG897 BE N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) DEUTSCHE BANK-SEOUL BRANCH N/A KR N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) UNICREDIT BANK AUSTRIA AG D1HEB8VEU6D9M8ZUXG17 AT N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) N Principal Shareholder Services, Inc. 084-05657 SEC File Number Y N DST Asset Manager Solutions, Inc. 084-00896 SEC File Number N Y N Principal Global Investors, LLC 549300BABIOZPCNHMB89 Y N N UBS SECURITIES LLC 8-16267 000008174 T6FIZBDPKLYJKFCRVK44 4981.00000000 MERRILL LYNCH PIERCE FENNER & SMITH 8-7221 000007691 DWW559HN8WVTCCS4VJ94 1898.47000000 CITIGROUP GLOBAL MARKETS 8-8177 000007059 MBNUM2BPBDO7JBLYG310 5281.39000000 GOLDMAN SACHS CO. 8-129 000000361 FOR8UP27PHTHYVLBNG30 1821.31000000 SANFORD C. BERNSTEIN & CO. 8-52942 000104474 549300I7JYZHT7D5CO04 1583.35000000 CREDIT SUISSE GROUP 8-00422 000000816 1V8Y6QCX6YMJ2OELII46 1794.09000000 M3 CAPITAL PARTNERS 8-47198 000036368 549300670K07JRB5UQ40 13363.35000000 MORGAN STANLEY & CO. LLC. 8-15869 000008209 9R7GPTSO7KV3UQJZQ078 2636.09000000 RBC DOMINION SECURITIES CORP. 8-45411 000031194 549300LCO2FLSSVFFR64 4170.65000000 J.P. MORGAN SECURITIES LLC 8-35008 000000079 8I5DZWZKVSZI1NUHU748 2197.68000000 54710.21000000 CREDIT SUISSE GROUP 8-00422 000000816 1V8Y6QCX6YMJ2OELII46 4478768.44000000 DEUTSCHE BANK SECURITIES CORP. 8-17822 000002525 9J6MBOOO7BECTDTUZW19 8732277.97000000 MERRILL LYNCH PIERCE FENNER & SMITH 8-7221 000007691 DWW559HN8WVTCCS4VJ94 3307226.57000000 J.P. MORGAN SECURITIES LLC 8-35008 000000079 8I5DZWZKVSZI1NUHU748 5345550.52000000 WELLS FARGO SECURITIES LLC 8-65876 000126292 VYVVCKR63DVZZN70PB21 8583605.87000000 BARCLAYS CAPITAL INC. 8-41342 000019714 G5GSEF7VJP5I7OUK5573 8152183.75000000 MORGAN STANLEY & CO. LLC. 8-15869 000008209 9R7GPTSO7KV3UQJZQ078 8908268.34000000 BANCAMERICA SECURITIES INC. 8-35968 000017977 N/A 2424521.25000000 GOLDMAN SACHS CO. 8-129 000000361 FOR8UP27PHTHYVLBNG30 7881707.15000000 CITIGROUP GLOBAL MARKETS 8-8177 000007059 MBNUM2BPBDO7JBLYG310 5437968.33000000 111525598.81000000 Y 104080390.02000000 Other Institutional Shares of beneficial interest Other Class Y Shares of beneficial interest Other Class A Shares of beneficial interest N N N N N N 0.01430000 0.01940000 N/A 19.35000000 true false ITEM 405 REG S-K 2 Section16_G.1_V2.htm G.1.B.IV SECTION Submission Proof - C:\Users\h370161\AppData\Local\Temp\SECPub.temp\Publish\123_N-Q.xml

Section 16(a) Beneficial Ownership Reporting Compliance

Section 30(h) of the 1940 Act and Section 16(a) of the 1934 Act require the Registrant’s trustees and executive officers, investment adviser, affiliated persons of the investment adviser, and persons who own more than 10% of a registered class of the Registrant’s equity securities to file Section 16(a) forms with the SEC reporting their affiliation with the Registrant, their ownership, and changes in their ownership of the Registrant’s shares. Those persons and entities are required by SEC regulations to furnish the Registrant with copies of all Section 16(a) forms they file or those filed on their behalf. Based solely on a review of those Section 16(a) forms furnished to it, the Registrant believes that all such filing requirements were met on a timely basis during the last fiscal year, except with respect to the filings described below.

On July 15, 2019, a Form 3 was filed on behalf of Andrew Donohue, an affiliated person of the Registrant’s investment adviser. That filing should have been made by July 5, 2019.

On December 9, 2019, a Form 3 was filed on behalf of Principal Life Insurance Company, a 10% beneficial owner of the Registrant. That filing should have been made by August 16, 2019.

On December 10, 2019, a Form 3 was filed on behalf of Principal Financial Services, Inc., a 10% beneficial owner of the Registrant. That filing should have been made by July 5, 2019.

On December 9, 2019, a Form 3 was filed on behalf of Principal Global Investors, LLC, the Registrant’s investment adviser. That filing should have been made by July 5, 2019.

Classification: Internal Use

OTHER REQUIRED INFO 3 Mgmt_Response_V2.htm MANAGEMENT RESPONSE Submission Proof - C:\Users\h370161\AppData\Local\Temp\SECPub.temp\Publish\123_N-Q.xml

Principal Funds
711 High Street, Des Moines, IA 50392
515 247 5111 tel
www.principal.com

May 20, 2020

Management has developed a plan to remediate the material weakness. Greater coordination of communication of information relevant to the valuation of private funds has been stressed for the Advisor’s portfolio management team. In conjunction with such coordination, the Advisor’s pricing group (responsible for monitoring the daily pricing process for all securities of the Registrant) has taken steps to help ensure that the Advisor’s financial reporting team (the group responsible for the preparation of the Registrant’s financial statements and reports) receive notification of each preliminary and final reported net asset value of a private fund in order to assess the impact of any change to financial statements and other regulatory filings. The pricing group is also enhancing reporting to the Registrant’s valuation committee through establishment of reporting thresholds for net asset value variances of a private fund and provision of summaries of any variances to the valuation committee for review. In addition, the pricing group will undertake to confirm unchanged net asset values with the portfolio management team on a periodic basis. The Registrant’s pricing group will also undertake to accelerate the review by a pricing consultant at annual and semi-annual period ends. This accelerated review will require the portfolio managers promptly to complete quarterly due diligence assessments.

INTERNAL CONTROL RPT 4 Internal_Control_EY_V2.htm INTERNAL CONTROL/EY Submission Proof - C:\Users\h370161\AppData\Local\Temp\SECPub.temp\Publish\123_N-Q.xml

Report of Independent Registered Public Accounting Firm

To the Shareholders and Board of Trustees
Principal Diversified Select Real Asset Fund

In planning and performing our audit of the financial statements of Principal Diversified Select Real Asset Fund (the Fund) as of and for the period from June 25, 2019, date operations commenced, through March 31, 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 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 U.S. 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 U.S. 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 a 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 the following deficiency involving the control environment and its operation that we consider to be a material weakness as defined above. This deficiency was considered in determining the nature, timing and extent of the procedures to be performed in our audit of the financial statements of the Fund as of and for the period from June 25, 2019, date operations commenced, through March 31, 2020, and this report does not affect our report on the financial statements of the Fund dated May 21, 2020. Private investment funds held by the Fund are valued at the net asset value provided by the investment manager of the private investment funds, subject to appropriate investment and operational due diligence review, in accordance with the Fund’s valuation policy. As of March 31, 2020, a material weakness existed in the operating effectiveness of the control related to the investment and operational due diligence review, which is designed to provide all available information to the Fund’s Valuation Committee in order for a fair value determination to be made. Based on this available information not being shared on a timely basis, the control over the Fund’s valuation of private investment funds did not operate effectively.

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/ Ernst & Young LLP

Minneapolis, Minnesota
May 21, 2020