October 9, 2019
SEC,
I believe a closed-end funds annual report should be amended to include a full description of the funds objectives, main strategies and main risks.
Many closed-end funds do not maintain a current registration statement, which would otherwise include this information. If there is a change to an objective, strategy or risk in the past year, they describe the change in the annual report. However, there is no complete description of a funds current objectives, strategies and risks. To learn this information, an investor would need to look at the funds most recent registration statement (which could be from decades ago) and review each annual report since that time. As an annual report is already about 100 pages (and mostly filled with less relevant information), I believe a funds current objectives, strategies, and risks should be disclosed.
Also, a fund should not be permitted to changes its objectives, strategies and risks (for any fund, but in particular for funds that cannot be redeemed or sold) unless the board makes a finding (and describes that finding) that the change is consistent with a reasonable investors expectations (or there is shareholder approval). I have observed many funds change their essential character and do not believe that is appropriate.
Thank you,
Lourdes Peres