0001341004-17-000189.txt : 20170509 0001341004-17-000189.hdr.sgml : 20170509 20170403160732 ACCESSION NUMBER: 0001341004-17-000189 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20170403 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BLACKROCK ENHANCED CAPITAL & INCOME FUND, INC. CENTRAL INDEX KEY: 0001278895 IRS NUMBER: 000000000 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 BUSINESS PHONE: 800-441-7762 MAIL ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 FORMER COMPANY: FORMER CONFORMED NAME: BLACKROCK ENHANCED CAPITAL & INCOME FUND, INC DATE OF NAME CHANGE: 20070521 FORMER COMPANY: FORMER CONFORMED NAME: BLACKROCK CAPITAL & INCOME STRATEGIES FUND INC DATE OF NAME CHANGE: 20061018 FORMER COMPANY: FORMER CONFORMED NAME: CAPITAL & INCOME STRATEGIES FUND INC DATE OF NAME CHANGE: 20040205 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BlackRock Energy & Resources Trust CENTRAL INDEX KEY: 0001306550 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 BUSINESS PHONE: 888-825-2257 MAIL ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 FORMER COMPANY: FORMER CONFORMED NAME: BlackRock Global Energy & Resources Trust DATE OF NAME CHANGE: 20041020 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BlackRock Health Sciences Trust CENTRAL INDEX KEY: 0001314966 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 BUSINESS PHONE: (888) 825-2257 MAIL ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BlackRock Global Opportunities Equity Trust CENTRAL INDEX KEY: 0001320375 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 BUSINESS PHONE: 888-825-2257 MAIL ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BlackRock Enhanced Equity Dividend Trust CENTRAL INDEX KEY: 0001332283 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 BUSINESS PHONE: 888-825-2257 MAIL ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 FORMER COMPANY: FORMER CONFORMED NAME: BlackRock Enhanced Dividend Achievers Trust DATE OF NAME CHANGE: 20050706 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BlackRock International Growth & Income Trust CENTRAL INDEX KEY: 0001393299 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 BUSINESS PHONE: 888-825-2257 MAIL ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BlackRock Utility & Infrastructure Trust CENTRAL INDEX KEY: 0001528988 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 55 EAST 52ND STREET CITY: NEW YORK STATE: NY ZIP: 10055 BUSINESS PHONE: (800) 882-0052 MAIL ADDRESS: STREET 1: 55 EAST 52ND STREET CITY: NEW YORK STATE: NY ZIP: 10055 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BlackRock Science & Technology Trust CENTRAL INDEX KEY: 0001616678 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 BUSINESS PHONE: 302-797-2000 MAIL ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BlackRock Resources & Commodities Strategy Trust CENTRAL INDEX KEY: 0001506289 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 BUSINESS PHONE: 1-800-882-0052 MAIL ADDRESS: STREET 1: 100 BELLEVUE PARKWAY CITY: WILMINGTON STATE: DE ZIP: 19809 CORRESP 1 filename1.htm
 
 
 
 
 
 
 
 
 
 
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April 3, 2017                
 
 
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VIA EDGAR
Christine DiAngelo Fettig
Senior Staff Accountant
Division of Investment Management
Disclosure Review Office
Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549
RE:
BlackRock Closed-End Funds
Dear Ms. Fettig:
Thank you for your oral comments on February 14, 2017 regarding your Sarbanes-Oxley review of the 2015 annual reports for the BlackRock closed-end funds listed on Annex A attached hereto (the “Funds”). The Funds have considered your comments and authorized us to respond on their behalf as set forth below. Your oral comments are summarized in bold, followed by the Funds’ responses.
* * * * * * *
Christine DiAngelo Fettig
April 3, 2017
Page 2
 
Comments and Responses
1.
We note that certain funds that are identified as non-diversified companies in the annual report appear to have been diversified as of December 31, 2015. Please confirm whether any of these funds have been operating as diversified companies for more than three years and, if so, please confirm that any such companies will obtain shareholder approval in accordance with Section 13(a)(1) of the Investment Company Act of 1940 (the “1940 Act”) if it again desires to operate as a non-diversified company. See 1940 Act Rule 13a-1; Allied Capital Corp., No-Action Letter (January 3, 1989).
Each of BlackRock Health Sciences Trust (“BME”) and BlackRock Utility and Infrastructure Trust (“BUI”) has informed us that it has been operating as a diversified company for more than three years. Each of BME and BUI therefore confirms that it will not operate as a non-diversified company without first obtaining shareholder approval in accordance with Section 13(a)(1) of the 1940 Act.
We also note that BlackRock International Growth and Income Trust (“BGY”) is incorrectly identified as a non-diversified company in its annual report for the year ended December 31, 2015.  BGY will clarify that it operates as a diversified company in future shareholder reports.
2.
Item 4(c) of Form N-CSR requires the registrant to disclose the aggregate fees billed in each of the last two fiscal years for professional services rendered by the principal accountant for tax compliance, tax advice, and tax planning, as well as a description of the nature of the services comprising the fees disclosed. Please include a more detailed description of the nature of the services comprising the fees disclosed in response to this item in future Form N-CSR filings.
The Funds will make the requested change in future Form N-CSR filings.
3.
Item 8(a)(1) of Form N-CSR requires that certain biographical information regarding a fund’s portfolio managers be provided as of the date of filing the Form N-CSR, as opposed to as of the end of the fund’s most recently completed fiscal year. Please clarify in future Form N-CSR filings that the information provided in response to Item 8(a)(1) is provided as of the date of filing.
The Funds will make the requested clarification in future Form N-CSR filings.
Christine DiAngelo Fettig
April 3, 2017
Page 3

 
* * * * * * *
Should you have any additional comments or concerns, please do not hesitate to contact me at (617) 573-4836 or Tom DeCapo at (617) 573-4814.

 
Best regards,
   
 
/s/ Kenneth E. Burdon
   
 
Kenneth E. Burdon


Annex A
Registration Number
Fund
811-21656
BlackRock Energy and Resources Trust
811-21506
BlackRock Enhanced Capital and Income Fund, Inc.
811-21784
BlackRock Enhanced Equity Dividend Trust
811-21729
BlackRock Global Opportunities Equity Trust
811-21702
BlackRock Health Sciences Trust
811-22032
BlackRock International Growth and Income Trust
811-22501
BlackRock Resources & Commodities Strategy Trust
811-22991
BlackRock Science and Technology Trust
811-22606
BlackRock Utility and Infrastructure Trust