Internal control over financial reporting

The Trust confirms that the internal control report was re-filed on 4/30/26.

We acknowledge the Staff’s comment. In future Annual Reports on Form 10‑K and Quarterly Reports on Form 10‑Q, we will revise our disclosure under “Controls and Procedures” to explicitly state management’s conclusion regarding the effectiveness of our disclosure controls and procedures as of the end of the period covered by the report, as required by Item 307 of Regulation S‑K. 1 By way of example, we expect to include language substantially similar to the following (subject to updates as of each reporting date): “As of _______________, our management, with the participation of our Chief Executive Officer and Chief Financial Officer, evaluated the effectiveness of our disclosure controls and procedures, as defined in Rules 13a‑15(e) and 15d‑15(e) under the Exchange Act. Based on this evaluation, our Chief Executive Officer and Chief Financial Officer concluded that our disclosure…

A security exchange was not posted on settlement date causing a difference in total unrealized gain/loss. One client transaction was placed and it was adjusted prior to settlement date and therefore no reimbursements were necessary. Due to the lack of materiality, this was not disclosed in the Fund’s financial statements. 9. Comment: With respect to Multi-Select Securities Fund for Puerto Rico Residents it appears there is no disclosure regarding Accounting Standards Update 2023-07, Topic

UBS has been actively working on remediation and reconnection efforts following the cybersecurity incident that impacted Linedata in August 2025. Linedata is a third-party service provider providing software for mutual fund pricing and accounting services for UBS Trust Company of Puerto Rico (“UBSTCPR”), which acts as Fund Administrator for the funds. To ensure the utmost precaution, UBSTCPR had suspended all connectivity between UBS and Linedata after the incident. Linedata, with the support of the cybersecurity consultant Mandiant, conducted a thorough forensic investigation and set up a new, segregated environment on Amazon Web Services (AWS) to facilitate client reconnections. A cybersecurity risk assessment was completed, indicating that the cyber risk associated with reconnecting to the new environment was “below moderate,” while the business risk of staying disconnected was…

Future filings will properly reference the “Public Company Accounting Oversight Board”. 20.

A NAV error occurred with respect to Invesco Pennsylvania Municipal Fund for one day due to the improper application of a valuation for a manually priced fixed income security. The error was identified the following day by the Registrant during the daily review of manually priced securities, a key control within the valuation process. Upon review, the controls were deemed reasonable and have been reinforced and, where necessary, enhanced to prevent recurrence. Shareholder redemptions were reprocessed and the third-party administrator reimbursed the Fund for losses associated with shareholder subscriptions affected by the error. 4.

The Company respectfully acknowledges the Staff’s comment and notes that this disclosure was inadvertently omitted from its Form 10-K due to a typographical error. On December 10, 2025, the Company filed Amendment No. 1 to Annual Report on Form 10-K/A to disclose management’s assessment regarding the effectiveness of its internal control over financial reporting as of December 31, 2024. If you have any questions or further comments about this response, please contact me by email at thook@viantinc.com. Sincerely, Viant Technology Inc. By: /s/ Tim Vanderhook Name: Tim Vanderhook Title: Chief Executive Officer cc: (via email) Ritesh Patel (Viant Technology Inc.) Jenna Cooper (Latham & Watkins LLP) 4

The Trust will re-file the internal control report as requested.

We acknowledge the Staff’s request for our analysis related to the materiality of our adjustments recorded during the quarterly period ended September 27, 2025 (“Q3 2025”), and reflected in our Form 10-Q (“Q3 2025 10-Q”). In conducting our analysis, we followed the requirements under Accounting Standards Codification Topic 250, Accounting Changes and Error Corrections (“ASC Topic 250”), including paragraph 250-10-45-27, with regards to determining materiality for the purpose of reporting the correction of an error for both the interim and annual periods presented. Further, in connection with the filing of the Q3 2025 10-Q, we conducted a quantitative and qualitative assessment of the errors discussed below based on the guidance set forth in SEC Staff Accounting Bulletin Topic 1.M, Materiality (“SAB 1.M”), and Staff Accounting Bulletin Topic 1.N, Considering the Effects of Prior Year…

We acknowledge the Staff’s request for our analysis related to the materiality of our adjustments recorded during the year ended December 28, 2024, and reflected in our Form 10-K (“2024 10-K”). In conducting our analysis, we followed the requirements under ASC Topic 250, including paragraph 250-10-45-27, with regards to determining materiality for the purpose of reporting the correction of an error for both the interim and annual periods presented. Further, in connection with the filing of the 2024 10-K, we conducted a quantitative and qualitative assessment of the errors discussed below based on the guidance set forth in SAB 1.M and SAB 1.N, and determined that their effects on the Company’s consolidated financial statements for the relevant prior periods were not material. I. Errors We identified errors in the Company’s consolidated financial statements when preparing the annual…

The Company respectfully acknowledges the Staff’s comment and confirms that in connection with management’s evaluation of the Company’s internal control over financial reporting as of the end of the period ending December 31, 2024, management concluded that as of such date, our internal control over financial reporting was effective. In addition, the registered public accounting firm that audited the financial statements included in our Form 10-K issued an attestation report that included an opinion that we maintained, in all material respects, effective internal control over financial reporting as of December 31, 2024, based on criteria established in the 2013 Internal Control – Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission. The Company will also include statements in future filings disclosing management’s conclusions as to the…

We respectfully acknowledge the Staff’s comment. We concluded that the potential magnitude of the errors that could have resulted from the control deficiency was limited to the amounts of the actual errors because there is no reasonable possibility of a greater magnitude of errors relating to the control deficiency in question rising to the level of a material misstatement. Rather, the Company has concluded that there was only a remote possibility of the occurrence of “additional transactions of a similar nature during each of the prior periods when the errors occurred,” therefore inherently limiting the potential magnitude of the errors resulting from the relevant control deficiency. The Company had only one owned corporate headquarters, and no additional real estate assets on its books outside of the corporate headquarters, making that sale transaction unique and not subject to…

The Trust will undertake to include the correct period in Section 4(d) of the certification as required by Form N-CSR with respect to future N-CSR filings. * * * Please contact me at (913) 660-0778 regarding the responses contained in this letter. Sincerely, /s/ John H. Lively John H. Lively

The Company acknowledges the Staff’s comment and respectfully advises that the Company intends to include the requested information in “Item 2. Properties” in its Form 10-K for the fiscal year ending December 31, 2025, which the Company expects to file with the Commission in February 2026. Please see the section titled “Proved Reserves Evaluation and Review of Estimated Proved Producing Reserves” in the attached Annex B for an example of the Company’s planned disclosure.

Fund Management has confirmed with Ernst & Young LLP, the Funds’ auditor, that the Internal Control Letter was intended to cover consolidated financial statements of the FS Multi-Strategy Alternatives Fund and the FS Alternatives Fund (Cayman). Ernst & Young LLP has confirmed that, going forward, the Internal Control Letter shall clearly disclose that the Internal Control Letter is intended to cover the consolidated financial statements for both the FS Multi-Strategy Alternatives Fund and the FS Alternatives Fund (Cayman). * * * * * SEC

The Company acknowledges the Staff’s comment and has amended its Form 20-F for the year ended December 31, 2024 to include separate conclusions of its principal executive officer and principal financial officer regarding the effectiveness of (i) disclosure controls and procedures and (ii) internal control over financial reporting, as of the end of the period covered by the report, as required by Item 15(a) of Form 20-F. The amended Form 20-F is being filed concurrently with this response letter. Comment 3 : Form 20-F. Item 18. Consolidated Financial Statements

In response to the Staff’s comment, the Company has updated the disclosure on page 32 of the Amended Registration Statement. Please do not hesitate to contact James A. Prestiano of Loeb & Loeb LLP at (212) 407-4831 with any questions or comments regarding this letter. Sincerely, /s/ James A. Prestiano James A. Prestiano Senior Counsel cc: Scott Wallace, CEO ECD Automotive Design, Inc. David J. Levine, Esq.

We do not believe that the change in control of the Funds’ prior investment adviser or the related new advisory and sub-advisory contracts during the period constituted a change in internal controls over financial reporting. On January 1, 2024, a subsidiary of Franklin Resources, Inc. (“Franklin Templeton”) acquired Putnam U.S. Holdings I, LLC and its subsidiaries, including Putnam Investment Management, LLC and Putnam Investments Limited (the “Transaction”). Upon consummation of the Transaction, each Putnam entity, including the Funds’ adviser and sub-advisers, was unchanged, including the personnel and procedures overseeing internal controls over financial reporting. We note that there was no change in senior management of the advisory organization or in the portfolio managers responsible for the day-to-day management of the relevant funds immediately prior to, and immediately after,…

The fund auditors have been notified of the comment for purposes of future filings and consideration is being given to refiling the 12/31/24 Form N-CEN. NLFT Deer Park Total Return Credit Fund

On 6/3/2024, widely reported NYSE Arca issues occurred and trading was halted on a number of stocks in the market. Amongst that group was the ticker NUSI (Nationwide Nasdaq-100 Risk Managed ETF). Trading on the security resumed the same day, hours after the intial halt. Anchor Risk Managed Income Strategies fund owned 28,000 shares of NUSI that priced at an ICE reported close of $11.36, down approximately 50% from the 5/31/24 market close. This price was verified to the standard second source of Refinitiv as well as an additional third-party source, Marketwatch. This closing price was widely reported across all sources available to the advisor as well. Upon market open on 6/4/24, it was discovered that the exchanges had updated the final correct closing price on 6/3/24 to $23.95. The NAV impact resulting from the update to the security price was greater than 0.50% of Fund net assets. As…

The material weakness identified by the Fund auditors related to the Fund’s internal controls to prevent and/or detect errors in the calculation of interest income and related amortization adjustments to the cost basis of certain interest only securities held by the Fund during the year ended September 30, 2024. Adjustments, which had no effect to the net assets or net asset value per share, were recorded by the Fund to correct these misstatements in the Fund’s September 30, 2024 financial statements. In response to the material weakness, management has implemented controls to prevent and/or timely detect similar errors in the future which include; 1) receiving information for interest only securities from the adviser which will enable the calculation of interest income and related amortization adjustments in a more accurate manner; 2) an automated rule in the fund accounting system…

The Company notes the Staff’s comment and has attached to this response letter revised certifications that include language referring to the Company’s internal control over financial reporting. Upon confirmation from the Staff that it has no further comments on the Annual Report, the Company will amend the original filing of the Annual Report to include these amended certifications. ______________________________ Simpson Thacher & Bartlett llp -5- The Company has advised us that it and its management are responsible for the accuracy and adequacy of its disclosures. Please call me at 212-455-2579 with any questions you may have regarding the above responses. Sincerely, /s/ Juan Francisco Mendez Juan Francisco Mendez cc: Andi Carpenter Kevin Woody Ely Hayashi Hirahoka Javier Durand Claudia Bustamante EXHIBIT 12.1 CERTIFICATION PURSUANT TO SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002 I,…

In response to the Staff’s comment, the Company has revised the disclosure on page 31 of Amendment No. 3. ECD's Nasdaq Listing, page 42

In May 2024, an error was identified in the income accrual calculations for two preferred equity investments held by the Fund. Specifically, the Fund’s income accrual calculations were based solely on actual funded principal amounts and did not incorporate unique “Minimum Investment Amount” provisions contained in the respective preferred equity agreements. These provisions established higher deemed principal balances for compounding purposes, and therefore the accrued income was understated. As a result, the Fund’s NAV per share was understated by greater than $0.01 per share from June 9, 2023 through May 3, 2024. Upon discovery, the accrued return schedules and NAV per share calculations were corrected. A benefit/loss analysis was performed, and it was determined that the overall impact was a net loss to the Fund of approximately $14,000, which was reimbursed to the Fund by Fundrise…

The Trust confirms the correct name is “Aristotle/Saul Global Equity Fund.” The correct name will be used consistently in future shareholder reports. 6 .

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has updated the certifications on page [79] of the Amended Form 10-K, as requested. * * * If you have any questions regarding this letter, please contact Jeffrey Guzy at telephone (703) 216-8606 or via e-mail at jeffrey.guzy@cojaxoilandgas.com. Sincerely, /s/ Jeffrey J. Guzy

In response to the Staff’s comment, the Company has revised the disclosure on pages 83, and 84 of the Amendment No. 2. 2 Please do not hesitate to contact James A. Prestiano of Loeb & Loeb LLP at (212) 407-4831 with any questions or comments regarding this letter. Sincerely, /s/ James A. Prestiano James A. Prestiano Senior Counsel cc: Scott Wallace, CEO ECD Automotive Design, Inc. David J. Levine, Esq. 3

The Company takes note of the Staff’s comment. We respectfully note that management did evaluate both disclosure controls and procedures (DCP) and internal control over financial reporting (ICFR) as of December 31, 2024, and concluded that both were effective. The intent of our Item 15 disclosure was to cover both, and we believe the Company’s 2024 Form 20-F was not misleading in substance. We understand, however, the Staff’s position that Item 15 requires separate, explicit conclusions on the effectiveness of DCP and ICFR. In future Form 20-F filings, we will revise our presentation to provide two distinct conclusions, one for DCP and one for ICFR, to align fully with Item 15. Because management’s evaluations and conclusions were properly made and disclosed, and the Staff’s comment concerns the structure rather than the substance of our disclosure, we respectfully request that this…

The Company respectfully acknowledges the Staff’s comment and advises that in connection with the preparation and filing of the Annual Report on Form 10-K for the fiscal year ended December 31, 2024 (as amended, the “Form 10-K”), the Quarterly Report on Form 10-Q for the quarter ended March 31, 2025 (the “Q1 10-Q”) and the Quarterly Report on Form 10-Q for the quarter ended June 30, 2025 (as amended, the “Q2 10-Q,” and together with the Form 10-K and the Q1 10-Q, the “Periodic Reports”), the Company, with the participation of its Chief Executive Officer, Chief Financial Officer (“CFO”) and solely with respect to the Form 10-K, its Interim CFO, evaluated the effectiveness of the Company’s internal control over financial reporting (as defined in Rule 13a-15(f) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”)) and disclosure controls and procedures (as defined in…

The Company acknowledges the Staff’s comment. In addition to the material weakness in our internal control over financial reporting related to the review of our inputs to the depreciation, depletion, and amortization calculations, there was also a material weakness identified by our auditors during their review of our tax provision calculation provided by our outsourced tax provision preparer. FOIA CONFIDENTIAL TREATMENT REQUESTED BY PEDEVCO CORP PURSUANT TO RULE 83 (PED- 22 ) Securities and Exchange Commission August 25, 2025 Page 23 The material weakness was due to a lack of a reconciliation between the provision tax basis to the tax return, primarily related to the tax basis of the Company’s oil and gas properties, which created an unidentified historical return to provision adjustment in the previous year. However, in the previous year, the impact was a footnote-only disclosure…

During 2024 when reviewing the impact on the VP ProFunds for the change in control of an insurance company shareholder for the year ended December 31, 2023, it was determined that the calculation of the December 31, 2022 capital loss carryforward (“CLCF”) for the ProFund VP Rising Rates Opportunity (the “Fund”) was incorrect, which caused the calculation of the required spillback distribution for the Fund for the December 31, 2022 fiscal year end to be understated. As a result, the December 31, 2022 annual shareholder report for the Fund disclosed an incorrect net capital loss carryforward amount in the Federal Income Tax Information section of the notes to the financial statements. To correct the understatement of the spillback distribution and maintain the Fund’s RIC qualification under the Internal Revenue Code (“IRC”), the Advisor considered multiple options such as the payment of a…

The Company acknowledges the Staff’s comment and respectfully advises the Staff that on August 20, 2025, the Company filed amendments to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2024 and Quarterly Report on Form 10-Q for the fiscal quarter ended March 31, 2025 to revise its conclusions on the effectiveness of disclosure controls and procedures and internal control over financial reporting. U.S. Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing August 20, 2025 Page 2 If you should have any questions concerning the enclosed matters, please feel free to contact our counsel, Jonathan M. Barron of K&L Gates LLP, at jonathan.barron@klgates.com or by telephone at (212) 536-3915 or Justin H. Kleckner of K&L Gates LLP, at justin.kleckner@klgates.com or by telephone at (615) 514-1806. Sincerely, /s/ Li Wai Chung Li…

The certifications have been revised in the Amended 10-K and the Amended 10-Q in accordance with the Staff’s comments. Please call me at 212-407-4866 if you would like additional information with respect to any of the foregoing. Thank you. Sincerely, /s/ Giovanni Caruso Giovanni Caruso Partner

In response to your comment, information about the NAV error for the Emerging Markets Debt Fund, including the nature and circumstances of the error, associated internal controls, mitigating actions and amounts reimbursed, will be provided supplementally and confidentially via letter dated August 7, 2025. ©2025 SEI Page 4 of 4 * * * * * * * Very truly yours, /s/Glenn Kurdziel Glenn Kurdziel Controller and Chief Financial Officer (Principal Financial Officer) cc: Robert A. Nesher Stephen Panner Timothy D. Barto ©2025 SEI

In response to the Staff’s comment, we have revised our disclosure on page 204 in Revised Registration Statement No. 3 to include the disclosure of “ our disclosure controls and procedures were not effective, due to the material weakness in our internal controls as a result of inadequate segregation of duties within accounting processes due to limited personnel and insufficient written policies and procedures for accounting, IT, and financial reporting and record keeping .” 1 Industry Overview of Hydrogen Energy, page 205

The Company acknowledges the Staff’s comment and has revised the disclosure on page 2 of the Form 10-K/A consistent with the requirements of Item 307 of Regulation S-K to provide the conclusions of the Company’s management regarding the effectiveness of its disclosure controls and procedures as of the end of the period covered by the Form 10-K. Please do not hesitate to contact me by telephone at (512) 617-0661 with any questions or comments regarding this correspondence. Sincerely, /s/ John Hensley John Hensley of MORRISON & FOERSTER LLP c.c.: (via email) Michael D. Hill, Chief Financial Officer, Upland Software, Inc. Ryan Adams, Morrison & Foerster LLP

The Company respectfully acknowledges the Staff’s comment and will revise future annual and quarterly filings as the Staff directs. Exhibit 32.2, page 52

The Company confirms that in connection with its evaluation of the effectiveness of its Disclosure Controls (as defined by the Company in Item 9A of the Form 10-K) as of December 28, 2024, the Company concluded, as of such date, that its Disclosure Controls were effective. ​ As discussed in our phone call on July 11, 2025, in future filings, we will include and disclose management's conclusions as to the effectiveness of our disclosure controls and procedures in accordance with the requirements of Item 307 of Regulation S-K. ​ Form 8-K Furnished April 28, 2025 Exhibit 99(a), page 7 ​

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has included the required disclosure in the Revised Form 10-K. Please contact Julian Seiguer of Kirkland & Ellis LLP at (713) 836-3334 with any questions or further comments regarding the responses to the Staff’s comments. Sincerely, STARDUST POWER INC. /s/ Roshan Pujari Name: Roshan Pujari Title: Chief Executive Officer Enclosures cc: Julian J. Seiguer, P.C., Kirkland & Ellis LLP Billy Vranish, Kirkland & Ellis LLP 2

The Registrant confirms that the internal control report on Form N-CEN for LFI should note that the financial statements are consolidated for Lazard Real Assets Portfolio. The internal control reports in future filings will indicate that the Lazard Real Assets Portfolio’s financial statements are consolidated.

In November 2023, the Trust became aware of a security setup issue by the Fund’s fund accounting service provider involving an inflation linked bond which was held in the Fund. The security setup failed to account for large increases in inflation rates and therefore, the bond’s original face did not reflect the accumulated increase in the position which caused the bond’s market value to be understated. As a result, for numerous days for the period ending October 31, 2022 and October 31, 2023, the NAV of the Fund had to be restated, and shareholder transactions were reprocessed as appropriate. Consequently, there was a loss to the Fund of $8,144.32 which was reimbursed to the Fund by the fund accounting service provider. Both the Trust and fund accounting service provider have put additional procedures and reconciliations in place to ensure all securities are set up correctly. The lack…

The Company amended page 80 of the Amendment and refile Exhibit 12 & 13 in response to the Staff’s comments.

The Company amended page 80 of the Amendment in response to the Staff’s comments. Please contact the undersigned at (852) 3923-1188 if you have any questions with respect to the response contained in this letter. Sincerely, /s/ Lawrence Venick Lawrence Venick Partner cc: Huajian Xu Chief Executive Officer LOBO EV Technologies Ltd.

The certifications will be revised accordingly in future reports on Form N-CSR. * * * Please call me at (312) 609-7616 if you have any questions. Very truly yours, /s/ Renee M. Hardt Renee M. Hardt Shareholder RMH/ser cc: Eric V. Hannemann

Certain invoice and fulfilment reconciliations with customers and general ledger entries took longer to complete than desired over the course of the fiscal year ending December 31, 2024. The invoice reconciliation process with the Company’s largest customer, Kimberly Clark de Mexico (KCM), in particular, sometimes took longer to complete than typical business practices due to KCM requirements for original documentation and multiple levels of internal approvals. The Company has worked with KCM to speed up necessary reconciliations through process improvements and technological automations, but certain internal KCM requirements have, at times, remained as bottlenecks. This has been the primary challenge to our internal controls over financial reporting. 7 Despite this challenge, the Company’s management team is confident in the resulting accuracy of the financial reporting completed for…

The Registrants acknowledge this comment and confirm that they will include the city and state where issued in the independent public accountant’s report on internal control in future filings.

The material weakness identified in the internal control report attached to the Form N-CEN related to the improper accounting of the Fund’s net investment income based Q3 2023 incentive fee, resulting in net assets being overstated by 0.47%-1.22% for the period July 1, 2023 to July 22, 2024. In accordance with trust procedures and following a formal analysis, shareholder activity was reprocessed and the Fund reimbursed for any losses sustained. Following a review and assessment by management, the December 31, 2023 semi-annual report was restated and subsequently filed as an amended Form N-CSRS on October 25, 2024. In response to the material weakness, Ultimus has developed and successfully implemented a macro which enables the incentive fee amount to be calculated automatically on a daily basis according to the terms of the incentive fee with a corresponding entry posted to the…

The Company respectfully acknowledges that the introductory language in paragraph 4 regarding the officers’ responsibilities for establishing and maintaining internal control over financial reporting was inadvertently excluded from the certifications filed as Exhibits 12.1 and 12.2 to the Form 20-F. The Company will revise future filings to ensure each Section 302 certification includes all the prescribed language set forth in paragraph 12 of the "Instructions as to Exhibits" of Form 20-F. We appreciate the Staff’s time and attention on this matter. If you have any questions or comments regarding the foregoing, please do not hesitate to contact me. Sincerely, /s/ Andrew E. Page Andrew E. Page Chief Financial Officer

In response to the Staff’s comment, the Company has revised the relevant exhibits. * * * The Company acknowledges that the Company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the Staff. We thank the Staff for its review of the foregoing. If you have questions or further comments, please forward them by electronic mail to Mr. Guojian Chen at guojian.chen@infinity-star.com . Very truly yours, /s/ Guojian Chen Guojian Chen Chief Executive Officer, Chief Financial Officer and Director 2

In response to Staff's comment, the Company has expanded the individual property disclosure under Item 4.E in order to provide the information regarding internal controls related to the Company's resource estimates for each of the Eau Claire Project and the Committee Bay Project. Item 19 Exhibits 15.2, page 140

The Company respectfully confirms that future filings of its annual report on Form 20-F will include the required disclosures in the format as follows: ITEM 15. CONTROLS AND PROCEDURES Disclosure Controls and Procedures Evaluation Under the supervision and with the participation of our management, including our chief executive officer and chief financial officer, we carried out an evaluation of the effectiveness of our disclosure controls and procedures, which is defined in Rule 13a-15(e) of the Exchange Act, as of December 31, 2024. Based on that evaluation, our chief executive officer and chief financial officer concluded that our disclosure controls and procedures as of December 31, 2024, were not effective. Management’s Annual Report on Internal Control over Financial Reporting Our management, including our chief executive officer and chief financial officer, is responsible for…

The Form N-CSR, Item 16b, did not clearly indicate the time-period covered by the statement. This will be more clearly stated in future files. Regarding the Dec 31, 2024 filing, the below statement is true: “There were no material changes to the internal controls over financial reporting (as defined in Rule 30a-3(d) under the Act (17 CFR 270.30a-3(d)) that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting.”

The Company respectfully acknowledges the Staff’s comment regarding the reference to the exclusion of Watermark Lodging Trust (“ Watermark ”) from management’s report on internal control over financial reporting (“ ICFR ”). The Company advises the Staff that reference to Watermark was made in error and should not have been designated as excluded from the Company’s ICFR assessment in reliance on Question 3 of the FAQ for Management’s Report on Internal Control over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports. The Company confirms to the Staff that as of December 31, 2024, the Company appropriately included all subsidiaries of the Company required for purposes of making its assessment on internal controls over financial reporting consistent with the rules of the Commission and applicable Commission guidance and there were no consolidated…

The Company has amended the Form 10-K/A to include a statement under Management's Annual Report on Internal Control over Financial Reporting to the effect that, based on our evaluation of internal controls, management concluded that the Company's internal control over financial reporting was not effective as of December 31, 2024 given the material weaknesses in our disclosure controls. Management is in the process of addressing these concerns to bring our controls and procedures in compliance with applicable rules. We trust the foregoing answers are responsive to your comments. Please do not hesitate to contact me at 312-955-0512 with any questions or comments regarding is correspondence. Yours truly, /s/ Shaun Passley Dr. Shaun Passley

The Registrant supplementally submits that the Goldman Sachs Global Core Fixed Income Fund’s former name (Goldman Sachs Global Income Fund) was inadvertently listed in Appendix A of the internal control report instead of the Fund’s current name. The Registrant confirms that an amended Form N-CEN was filed with the Securities and Exchange Commission via EDGAR on May 22, 2025 to update the independent public accountant’s internal control report to list the Goldman Sachs Global Core Fixed Income Fund. 8.

On November 8, 2024, the Goldman Sachs Energy Infrastructure Fund’s custodian, State Street, misstated the NAV of the Fund due to an incorrectly recorded dividend on an underlying MLP position held in the Fund, resulting in a material Fund NAV error to all share classes. The investment adviser to the Fund identified the issue on the next business day, November 11, 2024, and promptly notified State Street. Investor redemption transactions were reprocessed and the Fund’s performance was restated for November 8, 2024. State Street subsequently reimbursed the Fund for a loss of approximately $10,300. Since the amount of the reimbursement from the error was immaterial to the Fund and the source of the reimbursement was from State Street, which is not an affiliate of the Fund, no disclosure was required to be made in the Fund’s financial statements pursuant to ASC 946-20-05-2. As a result of…

The Registrant has filed the amended N-CSR as requested and will ensure that the certifications are updated for the future. 2.

The Company’s current evaluation of disclosure controls and procedures is the responsibility of both the Company’s President, who also serves as Chief Executive Officer, and the Vice President, who also serves as Chief Financial Officer. Item 9A mistakenly only included the Company’s President and Item 9A should be expanded to reflect the involvement of both individuals in the evaluation process. Financial Statements Note 2 - Summary of Significant Accounting Policies Mine Exploration and Development Costs, page F-9 4.

The Company has amended the Form 10-K to include a statement to the effect that. during the last fiscal quarter, there were no changes in our internal control over financial reporting identified in connection with management’s evaluation of the effectiveness of our internal control over the financial reporting that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act. We trust the foregoing answers are responsive to your comments. Please do not hesitate to contact me by telephone at (312) 285-1043 or via email at shaun@epazz.net with any questions or comments regarding is correspondence. Yours truly, /s/ Shaun Passley, PhD Shaun Passley PhD, CEO Ameritek Ventures, Inc.

The Registrant has filed an amended Form N-CEN reflecting the Staff’s comments. * * * Please do not hesitate to contact the undersigned at (202) 261-3402 with any questions or comments concerning this correspondence. Sincerely, /s/ Alexander C. Karampatsos Alexander C. Karampatsos cc: Nauman S. Malik, Eagle Point Credit Management LLC Joshua M. Katz, Eagle Point Credit Management LLC Brooke A. Clark, Eagle Point Credit Management LLC Philip T. Hinkle, Dechert LLP Antonio G. Fraone, Dechert LLP