Liquidity and capital resources

5. In your February 5, 2026 earnings call, management spent time discussing some “short-term industry-wide policy headwinds” that are impacting client budgets and advertising booking rates for pharmaceutical companies. Management also indicated that higher AI infrastructure investment has impacted the results through the period ended December 31, 2025 and is expected to continue impacting future periods. Please show us how you intend to revise to address (and quantify where possible) any known material trends, demands, commitments, events or uncertainties that are reasonably likely to result in a material change to your liquidity or results from operations. Please refer to Item 303(c) of Regulation S-K. 5

6. We note your disclosure that "we are not a 'shell Company' within the meaning of Rule 405;" however, it appears from your disclosure that you may be a shell company pursuant to Rule 405 under the Securities Act. In this regard, we note that you have no revenue, no customers or employees, and nominal operations. We also note that significant steps remain to commence your business plan. Please revise to explicitly disclose your status as a shell company and further disclose the consequences of that status, such as the restrictions on your ability to use registration statements on Form S-8, the limitations on the ability of your security holders to use Rule 144 and the potential reduced liquidity or illiquidity of your securities. Alternatively, explain to us why this is not necessary.

Comment 1: Will the Fund invest significantly greater than 15% in investments with limited liquidity? If so, please explain supplementally how the fund determined that its investment strategy is appropriate for an open-end structure. See Investment Company Liquidity Risk Management Programs, Investment Company Act Release No. 32315 (Oct. 13, 2016) (“Adopting Release”). Please also supplementally explain the Fund’s plan to manage liquidity under 22e-4 given the Fund’s strategy.

11. The Commission Staff notes that “Mortgage-related and other asset-backed securities risk” is listed as a principal investment risk. Please disclose any risks in the “Principal Investment Risks” section and related information in the “Principal Investment Strategies” section relating to investments in sub-prime mortgages. If applicable, please disclose the liquidity of sub-prime mortgages and of non-agency, non-investment grade mortgage and asset-backed securities and that they could dramatically change over time.

112. When choosing among offered Segment Options, consider which term lengths, limits on index gains, and limits on index losses may be appropriate for you based on your risk tolerance, liquidity needs, investment horizon, and financial goals. Consider that a Segment Option with a Segment Fee offers higher Cap Rates, Participation Rates, Downside Participation Rates, and Trigger Rates than the same Segment Option without a Segment Fee, which in turn provides you with the possibility of, but does not guarantee, greater growth potential. Also consider that an Index-Linked Segment Option with a higher Buffer Rate will tend to have a lower Cap Rate, Participation Rate, Downside Participation Rate, or Trigger Rate, as applicable, compared to a Segment Option with a lower Buffer Rate for the same Reference Index and Segment Term Period. This is because of the additional downside protection…

1. State the reasons for the timing of the going private transaction, taking into account that many of the conditions it is intended to address (costs of being a reporting company, lack of liquidity) have existed for some time. See Item 7 of Schedule 13E-3 and Item 1013(c) of Regulation M-A.

Comment. The Staff notes that “Liquidity Risk” is included in the risk disclosure corresponding to Item 4 of Form N-1A. To the extent that “Liquidity Risk” is a principal risk of investing in the Fund, please also include risk disclosure corresponding to Item 9 of Forn N-1A.

2. Please revise to provide additional disclosure regarding SOL and your staking plans. For example purposes only: ● Disclose your policies and procedures regarding your plans to stake Solana, including how much of your SOL you intend to stake. ● Revise to provide greater detail explaining how agreements with staking providers will operate. ● If material, add a risk factor addressing any liquidity risks related to your staking plans. ● Identify the custodians that hold and will hold your digital assets and disclose the material terms of the custody arrangements, including the amount and limitations of any insurance coverage.

16. You disclose that the Company was in compliance with all financial debt covenants as of December 31, 2024 and 2023. You further disclose that the Company received a waiver to waive any potential defaults or events of default that may have occurred and be continuing under the Credit Agreement. Please tell us and revise your Liquidity section in MD&A to discuss the specific circumstances that required a waiver, the potential effects, and the nature of the waiver. In light of the November 2025 refinancing of your debt, please also address in this Liquidity disclosure whether there is a similar covenant in your new debt agreement to assist your investors in evaluating the likelihood of future similar defaults. Please see guidance in Item 303(b)(1)(i) of Regulation S-K. Please include the interim period ended September 30, 2025 in your response and revised disclosure as we note similar…

3. Please revise to clearly disclose the risks that being based in China poses to investors. In particular, describe the significant regulatory, liquidity, and enforcement risks with cross-references to the more detailed discussion of these risks in the prospectus. For example, specifically discuss risks arising from the legal system in China, including risks and uncertainties regarding the enforcement of laws and that rules and regulations in China can change quickly with little advance notice; and the risk that the Chinese government may intervene or influence your operations at any time, or may exert more control over offerings conducted overseas and/or foreign investment in China-based issuers, which could result in a material change in your operations and/or the value of the securities you are registering for sale. Acknowledge any risks that any actions by the Chinese government to…

3. We note your revised disclosures in Amendment No. 3 submitted on November 7, 2025. Please revise to disclose the amount of minimum funding necessary to meet your operating needs for at least the next 12 months, as well as the minimum number of months that you will be able to conduct your planned operations using currently available capital resources. Refer to Item 303(b)(1) of Regulation S-K.

4. The Staff notes the liquidity screen described in the fifth paragraph set forth in the “Portfolio Selection Process” section. The inclusion of the liquidity screen as a factor in the selection of the portfolio suggests the Trust might be actively managed. Please supplementally confirm that there is no active management of the portfolio.

5. The Staff notes the following disclosure in the sixth paragraph set forth in the “Portfolio Selection Process” section, “Although the Analysts provide the list of common stocks to the Sponsor, the Sponsor may not select every common stock on the list for inclusion in the Trust based on the Sponsor’s liquidity screen above.” Please consider revising this disclosure to clarify whether all stocks on the Analysts’ list that meet the liquidity screen will be selected for the final portfolio.

7. Comment : Supplementally, please explain how call strategies and option writing and purchases are expected to impact the market of shares or units of Spot Ether ETFs. For example, are the liquidity of Spot Ether ETFs expected to be impacted and might it limit the available capacity of Spot ETFs?

15. Comment : Please consider adding/addressing the following to your general discussion of Ether Risk: ● Ethereum is an evolving blockchain platform that continues to undergo substantial upgrades, such as the transition from Proof-of-Work to Proof of-Stake Stake (the “Merge”) in 2022 and subsequent network improvements like the 2024 Dencun upgrade to reduce costs and improve scalability. These complex technological upgrades are intended to improve Ethereum’s scalability, security, transaction throughput, energy efficiency, and usability. However, each significant update introduces risks including technical vulnerabilities, potential software flaws, delays in development, operational disruptions, or unintended economic impacts, any of which could negatively affect investor confidence, the adoption of the Ethereum blockchain, or ether’s valuation. ● The regulatory environment for ether…

7. We note your risk factor disclosure that addresses the novelty of digital assets and the resulting risks, including commercial and technical uncertainty. There or in a new risk factor, please revise to enhance your disclosure by describing any material financing, liquidity, or other risks you face related to the impact that a crypto asset market disruption may have, directly or indirectly, on the value of ENA (including the staked version) or other digital assets you hold or intend to hold.

Comment 8 : “Equity Risk” includes the sentence “In addition, preferred securities may be subject to greater credit risk or other risks, such as risks related to deferred and omitted distributions, limited voting rights, liquidity, interest rates, regulatory changes and special redemption rights.” If investment in preferred stock is a principal investment strategy of the Fund, please disclose that in the Fund’s principal investment strategies. Alternatively, please tailor “Equity Risk” to the equity securities disclosed in the Fund’s principal investment strategies.

Comment 1: Please consider deleting the following language in the “Fund Shares Trading, Premium/Discount Risk and Liquidity of Fund Shares” risk disclosure. Otherwise, please supplementally explain the relevance of the disclosure for a money market fund. The investments held by the Fund may be traded in markets that close at a different time than the Exchange. Liquidity in those investments may be reduced after the applicable closing times. Accordingly, during the time when the Exchange is open but after the applicable market closing, fixing or settlement times, bid-ask spreads on the Exchange and the resulting premium or discount to the shares’ NAV may widen.

Comment 2: (A) Does the Registrant expect an investment in the Fund to qualify as a cash equivalent under US GAAP? Why or why not? (B) Would the answer change in stressed market conditions or in a material liquidity event in the US Treasury market such as a debt ceiling impasse?

Comment: Please advise supplementally whether the registrant expects an investment in the Fund to qualify as a “cash equivalent” for purposes of U.S. Generally Accepted Accounting 1 See e.g., BlackRock Summit Cash Reserves Fund, Prospectus (Aug. 22, 2023), available at https://www.sec.gov/ix?doc=/Archives/edgar/data/353281/000119312523217891/d475388d485bpos.htm; PGIM Government Money Market Fund, Prospectus (Sept. 29, 2023), available at https://www.sec.gov/ix?doc=/Archives/edgar/data/67590/000168386323006834/f36424d1.htm 2 Principles (“GAAP”). Please explain why or why not? Also address how this analysis would change in a stressed market or a material liquidity event in the U.S. Treasury market, such as a debt ceiling impasse event?

Comment: The second sentence of the sixth paragraph in the section states “[g]overnment money market Funds’ are required to invest at least 99.5% of their assets in…(iii) repurchase agreements that are collateralized fully and are exempt from requirements that permit money market funds to impose a liquidity fee.” Please clarify that such repurchase agreements must be “fully collateralized by cash and/or government securities”.

Comment : With respect to the first sentence of the “ Summary– Principal Risks of the Fund— Liquidity Risk ” disclosure, please confirm that the first part of the sentence (regarding investments illiquid investments) is accurate or revise as necessary.

Comment : In the same section referenced in Comment 4, please supplementally explain how the Fund plans to address any liquidity issues that may arise due to the potentially limited number of investors and large-scale redemptions generally.

5. We note your disclosure that “[w]e delegate (’stake’) a portion of our digital assets, primarily locked SOL, with third party validators… In some cases, we jointly own and operate validators alongside ecosystem partners to further align our treasury strategy with the broader Solana network.” Please revise to provide a materially complete description of your staking program. In this regard, please address each of the following points with respect to your (i) delegated staking activities with third party providers and (ii) staking activities conducted through your owned validators that you operate, as applicable: ● State whether you have any target percentage of your SOL holdings that you stake. ● Describe in greater detail the mechanics of the staking process. ● Disclose the material terms of your agreements with your staking providers, and summarize the responsibility and duties of…

5. We note your disclosure that "[w]e delegate ('stake') a portion of our digital assets, primarily locked SOL, with third party validators… In some cases, we jointly own and operate validators alongside ecosystem partners to further align our treasury strategy with the broader Solana network." Please revise to provide a materially complete description of your staking program. In this regard, please address each of the following points with respect to your (i) delegated staking activities with third party providers and (ii) staking activities conducted through your owned validators that you operate, as applicable: ● State whether you have any target percentage of your SOL holdings that you stake. ● Describe in greater detail the mechanics of the staking process. ● Disclose the material terms of your agreements with your staking providers, and summarize the responsibility and duties of…

7. Management’s Discussion and Analysis of Financial Condition and Results of Operations” focuses on current year results as opposed to results from the prior year. Please see the section titled “Operations” in attached Annex A for an example of the Company’s planned disclosure. U.S. Securities and Exchange Commission Division of Corporation Finance Office of Finance Office of Energy & Transportation October 10, 2025 Page 3 Non-GAAP Performance Measures, page 27 7. We note your presentation of a non-GAAP financial measure titled ‘Free Cash Flow’. Please address the following: · You identify Free Cash Flow as performance measure, but the label suggests it may be a liquidity measure. Tell us the specific facts and circumstances that led you to conclude this is a performance measure. If you continue to believe Free Cash Flow is a performance measure, tell us how you determined it is…

2. We note that you have a significant amount of cash on hand as of December 31, 2024. Please revise to provide a more substantive discussion of your material cash requirements from known and other obligations both in the short-term and separately in the long-term (beyond the next 12 months). As part of this analysis, identify any known trends, demands, commitments, events or uncertainties that are reasonably likely to materially impact your liquidity and capital resources. For example, we note from your Q4 2024 investor presentation that your future plans include an expansion of your core work product lines. Additionally, in your August 11, 2025 earnings call, management discussed investing in mondayDB. Your revised disclosures should address the timeline and expected cost of any known or anticipated investments along with the anticipated impact on your capital resources and liquidity.

Comment 11 : Please supplementally explain why Leverage and Volatility Risk and Liquidity Risk are repeated twice under Item 9. Please consider streamlining the disclosure. October 7, 2025 Page 5

7. We note that your press release filed as Exhibit 99.1 to your Form 8-K filed September 4, 2025, states that you “plan for the Solana to be staked including liquid staking tokenization to increase yields for shareholders in the long-term.” Please revise to address the following comments: ● Expand your disclosure to provide a materially complete description of your plans to stake Solana, engage in liquid staking, and any other methods by which you intend to generate yield. Without limitation and to the extent applicable, your disclosure should address the mechanics of the process, the participants involved, and how awards are determined or other profits generated as well as any risks associated with staking and other income-generating strategies and the impact of those risks to investors. Also disclose your policies and procedures for your staking plans, including, for example, how…

Comment 2. The Item 4 “Principal Investment Strategies” section of the Fund’s Prospectus states: The Sub-Adviser then evaluates CLOs in secondary markets ( i.e. , markets where the securities are traded following the initial offering), focusing on vintage, yield, rating, and liquidity relative to the Fund’s current investments, and with the goal of providing higher yields with lower defaults than similarly rated fixed income alternatives. Please revise this disclosure and similar disclosure in the Item 9 “Principal Investment Strategies” section to expand on what “rating” the Sub-Adviser will use when evaluating CLOs in the secondary markets. For example, if this disclosure refers to credit ratings, then please revise by inserting “credit” ratings in the disclosure.

Comment 2 : We note your response to prior comment 1. Under an appropriately captioned heading, please revise to provide a complete description of your liquidity risk policies and procedures. To the extent such policies and procedures are intended to be consistent with the exchange’s proposed generic listing standards, please confirm and revise your disclosure accordingly.

Comment 4 : We note your revised disclosure here in response to comment 1 that while the Trust may stake a maximum of 100% of its SOL holdings, the precise percentage to be staked will be based on the estimated liquidity needs of the Trust and other factors, as determined by the Sponsor. Please revise to quantify the percentage of the Trust’s SOL you intend to stake under normal circumstances in light of the liquidity needs and other factors you identify in your disclosure, or tell us why you are unable to do so. Please also tell us, with a view towards revised disclosure, whether a current percentage of the Trust’s SOL being staked will be made publicly available to investors on a regular basis, including on your website or otherwise.

Comment 5 : We note the revisions you made on page 28 in response to prior comment 4 and we reissue the comment. Refer to your disclosure that staked SOL is temporarily locked and inaccessible during the bonding and unbonding periods. Please revise here to disclose with specificity the bonding and unbonding periods associated with staking SOL, discuss how they affect liquidity and disclose the material terms of any policies and procedures you have in place to manage liquidity and maintain effective arbitrage in light of any staking program you undertake.

Comment 2 – Staking – Liquidity Policies and Procedures, page 85 We note your response to prior comment 3. Please confirm your understanding that we may have additional comments upon review of a materially complete description of your staking program liquidity risk policies and procedures.

1. Please revise your disclosure, consistent with your response, to clarify that your liquidity risk policies and procedures for your staking program are consistent with the exchange’s proposed generic listing standards.

3. Comment : You state here that the Sponsor has adopted a liquidity risk management policy (the “Policy”) related to the management of the Fund’s staking program and related liquidity risks. Please revise to clarify whether or not the disclosure in this section is a description of the Policy. Please also clarify which part of the Policy addresses whether the investment strategy is appropriate for effective and efficient arbitrage.

Comment : In the second bullet-pointed section, please add the following: · Investment in the Fund is suitable only for sophisticated investors and requires the financial ability and willingness to accept the high risks and lack of liquidity inherent in an investment in the Fund.

Comment 1 – Cover Page We note your revisions in response to comment 1 in which you state that under normal circumstances, the Sponsor will seek to stake all of the Trust’s SOL through one or more staking providers except for SOL reserved by the Sponsor in its sole discretion to facilitate foreseeable redemption transactions, pay Trust expenses or otherwise protect the Trust and its assets. Please revise to quantify the percentage of the Trust’s SOL you intend to stake under normal circumstances in light of the liquidity needs and other factors you identify in your disclosure, or tell us why you are unable to do so. Please also tell us, with a view towards revised disclosure, whether a current percentage of the Trust’s SOL being staked will be made publicly available to investors on a regular basis, including on your website or otherwise.

Comment 2 – Prospectus Summary – The Staking Provider, Page 7 We note your revised disclosure in response to prior comment 3. Please revise to clarify whether or not the disclosure in this section is a complete description of the Liquidity Risk Management Policy. Please also clarify which part of the policy addresses whether the investment strategy is appropriate for effective and efficient arbitrage. In addition, please discuss any fees involved, any limits to this feature, whether the Trust intends to use the “instant unbond” feature for all redemption requests, and whether the “instant unbond” feature involves receiving a receipt token in exchange for staked SOL. Please also revise to clarify if the spread on the instant unbond feature will reduce the amount of SOL represented by a Share and the value of the Shares.

Comment: The section “Fund details – Principal investment risks” includes a discussion of certain risks ( e.g., general obligations, revenue obligations, focus of investments, liquidity and illiquid investments, and, for all but Franklin Short-Term Municipal Income ETF, tender option bonds) that are not explicitly referenced in the section “Fund summary – Risks.” Please summarize these risks in the section “Fund summary – Risks.” Please also ensure that, to the extent appropriate, these topics are addressed in the discussion of the Fund’s principal investment strategy.

13. We also note that you indicate that BXPE may redeem up to 3% of the limited partnership interests outstanding (either by number of units or the NAV). Please clarify whether the determination to limit repurchases to either measurement is at the option of the General Partner, the extent that the total number of units that may be repurchased are materially different based on the two potential measurements. Additionally, we note your reference on page 3 to the unit redemption plan which BXPE U.S. intends to implement, as well as your references on pages F-12 and F-30 to the repurchase program BXPE U.S. has implemented. Please revise your disclosure to clarify whether the redemption and repurchase plans are separate liquidity programs, or advise.

11. For the FIS Bright Portfolios Focused Equity ETF, please consider grouping the ETF risks as sub-bullets under the principal risk heading of ETF Risk, as in FIS Christian Stock Fund. Please also ensure that the principal ETF risks for the FIS Bright Portfolios Focused Equity ETF include the following, in addition to the ETF risks already included: “That the Fund’s market price may deviate from the value of the Fund’s underlying portfolio holdings, particularly in times of market stress, with the result that investors may pay more or receive less than the underlying value of the Fund shares bought or sold. For clarity, consider disclosing that this can be reflected as a spread between the bid and ask prices for the Fund quoted during the day or a premium or discount in the closing price from the Fund’s NAV.” ● Please also note that in times of market stress, market makers or…

13. We note that you removed your comparison of the years ended September 30, 2024 and 2023. Please revise to include this information. In addition, in Liquidity and Capital Resources on page 195, revise to include a discussion of the years ended September 30, 2024 and 2023. Refer to Item 303 of Regulation S-K.

3. Disclose any associated risks that may arise with more volatile or speculative investments, conflicts of interest, and the liquidity of the private funds’ underlying investments.

4. Disclose that UPFs are not limited by the 1940 Act in how they invest their assets, such as with respect to leverage and transactions with affiliates; that investments in the UPFs may impact the strategies, risks, and costs of and for the Fund itself; and that Fund shareholders may or will have limited information about the UPFs in which the Fund invests, including with respect to the UPFs’ holdings, liquidity, and valuation.

5. Disclose, if material, risks relating to: the legal jurisdictions of the UPFs; any “liquidity terms” for the Fund’s private fund investments (such as mandatory minimum holding periods, limitations or suspensions of redemptions, and the possibility of “payment in kind” distributions in response to a redemption request) and how these terms may impact the fees, performance, and liquidity of the Fund.

Comment : If the Fund will invest in Private Funds as principal investment strategy, please revise the disclosure to include the following, if applicable: a. Please revise the disclosure to discuss the fees of Private Funds. When doing so, please also consider the effects of any Private Fund’s performance fees or incentive allocations on the Fund’s performance, including the possibility that some Private Funds may receive performance fees, even if other Private Funds or the overall performance of the Fund is negative. b. Please disclose the types of Private Funds in which the Fund proposes to invest in and the associated risks or considerations, including, to the extent material, the Private Fund’s investment strategies, risks associated with volatile or speculative investments, conflicts of interests and the liquidity of the Private Funds. c. Please add disclosure that Private Funds in…

4. Please revise to add separately captioned risk factors related to bitcoin and the bitcoin network, as well as any material financing, liquidity, or other risks you face related to the impact that a crypto asset market disruption may have, directly or indirectly, on the value of the bitcoin you hold.

4. Please revise to add separately captioned risk factors related to bitcoin and the bitcoin network, as well as any material financing, liquidity, or other risks you face related to the impact that a crypto asset market disruption may have, directly or indirectly, on the value of the bitcoin you hold.

4. Please disclose the risks that your corporate structure and being based in or having the majority of the company's operations in China poses to investors. In particular, describe the significant regulatory, liquidity, and enforcement risks. For example, specifically discuss risks arising from the legal system in China, including risks and uncertainties regarding the enforcement of laws and that rules and regulations in China can change quickly with little advance notice; and the risk that the Chinese government may intervene or influence your operations at any time, or may exert more control over offerings conducted overseas and/or foreign investment in China-based issuers, which could result in a material change in your operations and/or the value of your securities. Acknowledge any risks that any actions by the Chinese government to exert more oversight and control over offerings…

Comment : Please add the following bullet points: a. The Company’s common stock is not currently listed on an exchange, and it is uncertain whether a secondary market will develop. b. Repurchases of common stock by the Company, if any, are expected to be very limited. c. An investment in the Company may not be suitable for investors who may need the money they invest in a specified time frame. d. Investment in the Company is suitable only for sophisticated investors and requires the financial ability and willingness to accept the high risks and lack of liquidity inherent in an investment in the Company. e. The Company intends to invest primarily in privately-held companies for which very little public information exists. Such companies are also generally more vulnerable to economic downturns and may experience substantial variations in operating results. f. The privately-held companies…

2. Please disclose whether you have received the Sui Foundation’s approval to stake the SUI purchased pursuant to the Digital Asset Purchase and Sale Agreement, and, to the extent that you have begun to stake SUI, please disclose the percentage of your SUI holdings that are currently staked. Please also disclose the percentage you plan to stake going forward. In addition, please disclose the identities of your Staking Service Providers, disclose the material terms of your agreements with the Staking Service Providers, and include the agreements as exhibits to your registration statement if required by Item 601 of Regulation S-K. In addition, with a view towards revised disclosure, please tell us how you estimate that you will earn approximately 2.2% of the amount of staked SUI per year if “[t]he amount of SUI [you] receive as reward for [your] staking activity can vary significantly.”…

4. Please expand to disclose the impact to you and investors of PIPE issuances, including that the arrangements result in costs particular to the de-SPAC process that would not be anticipated in a traditional IPO. If true, disclose that the agreements are intended to ensure a return on investment to the investor in return for funds providing sufficient liquidity.

Comment: This risk factor describes the risks of private investment funds. Please review the disclosure describing the investment strategies and risk factors regarding private fund investments and confirm to us that all principal risks associated with investing in private investment funds have been adequately disclosed, including the following risks: (1) private funds have flexibilities not available to registered funds with respect to leverage and affiliated transactions; (2) private funds have complex fee structures including performance-based compensation beyond what is permitted to registered funds and those fees may be charged even when the private fund, or the Fund, loses money; (3) the Fund may have difficulty monitoring the operations and performance of the private funds because of, for example, limited access to information about private fund investments and valuation; (4)…

2. We acknowledge your response to prior comment 4 and reissue. Where you describe the significant regulatory, liquidity, and enforcement risks that the majority of your directors and officers being based in or having significant ties to China poses to investors, please revise to provide cross-references to the more detailed discussion of these risks in the prospectus.

Comment 6 – General Please explain supplementally to the Staff, and add disclosure if appropriate, how each Fund will maintain liquidity to meet redemptions and comply with rule 22e-4 under the Investment Company Act of 1940, as amended (the “1940 Act” ).

Comment 4 : Investments in Investment Companies Risk. The disclosure states “…if the Fund invests in pooled investment vehicles that are not registered under the Investment Company Act of 1940, as amended, such investments will not be afforded the regulatory protections established under U.S. law.” Please supplementally explain to the extent to which the Fund will invest in pooled investment vehicles and how it intends to comply with the Liquidity Rule. To the extent this is not a principal risk, please consider removing it. Mr. Raymond A. Be September 11, 2025 Page 2

Comment: The Fund discloses that it may enter into derivatives transactions, principally index futures, to manage liquidity as part of the Fund’s principal investment strategy. Accordingly, please revise the Derivatives Risk to include index futures.

Comment: The Fund discloses that it may enter into derivatives transactions, principally index futures, to manage liquidity as part of the Fund’s principal investment strategy. Accordingly, please revise the Derivatives Risk to include index futures.

Comment: The Fund’s Principal Investment Risks include Restricted Securities Risk and Liquidity Risk. Please add disclosure to the Fund’s Principal Investment Strategies section discussing the Fund’s use of restricted and illiquid securities.