0001752724-23-227652.txt : 20231013
0001752724-23-227652.hdr.sgml : 20231013
20231013105150
ACCESSION NUMBER: 0001752724-23-227652
CONFORMED SUBMISSION TYPE: N-CEN
PUBLIC DOCUMENT COUNT: 5
CONFORMED PERIOD OF REPORT: 20230731
FILED AS OF DATE: 20231013
DATE AS OF CHANGE: 20231013
EFFECTIVENESS DATE: 20231013
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Arrow Investments Trust
CENTRAL INDEX KEY: 0001527428
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FISCAL YEAR END: 0731
FILING VALUES:
FORM TYPE: N-CEN
SEC ACT: 1940 Act
SEC FILE NUMBER: 811-22638
FILM NUMBER: 231324242
BUSINESS ADDRESS:
STREET 1: 6100 CHEVY CHASE DR
STREET 2: SUITE 100
CITY: LAUREL
STATE: MD
ZIP: 20707
BUSINESS PHONE: 301-260-0162
MAIL ADDRESS:
STREET 1: 6100 CHEVY CHASE DR
STREET 2: SUITE 100
CITY: LAUREL
STATE: MD
ZIP: 20707
0001527428
S000035948
Arrow DWA Tactical: Balanced Fund
C000110176
Arrow DWA Tactical: Balanced Fund Class A Shares
DWAFX
C000110177
Arrow DWA Tactical: Balanced Fund Class C Shares
DWATX
C000110178
Arrow DWA Tactical: Balanced Fund Institutional Class Shares
DWANX
0001527428
S000035949
Arrow DWA Tactical: Macro Fund
C000110179
Arrow DWA Tactical: Macro Fund Class A Shares
DWTFX
C000110180
Arrow DWA Tactical: Macro Fund Class C Shares
DWTTX
C000110181
Arrow DWA Tactical: Macro Fund Institutional Class Shares
DWTNX
0001527428
S000035950
ARROW MANAGED FUTURES STRATEGY FUND
C000110182
ARROW MANAGED FUTURES STRATEGY FUND CLASS A SHARES
MFTFX
C000110183
ARROW MANAGED FUTURES STRATEGY FUND CLASS C SHARES
MFTTX
C000110184
ARROW MANAGED FUTURES STRATEGY FUND INSTITUTIONAL CLASS SHARES
MFTNX
0001527428
S000041726
Arrow DWA Tactical: Macro ETF
C000129549
Arrow DWA Tactical: Macro ETF
DWAT
0001527428
S000059857
Arrow DWA Tactical: International ETF
C000195837
Arrow DWA Tactical: International ETF
0001527428
S000071897
Arrow Reverse Cap 500 ETF
C000227510
Arrow Reverse Cap 500 ETF
N-CEN
1
primary_doc.xml
X0404
N-CEN
LIVE
0001527428
XXXXXXXX
811-22638
false
false
N-1A
S000059857
C000195837
S000035950
C000110183
C000110184
C000110182
S000035949
C000110181
C000110179
C000110180
S000071897
C000227510
S000041726
C000129549
S000035948
C000110176
C000110177
C000110178
ARROW INVESTMENTS TRUST
811-22638
0001527428
549300IHK71DVRHETY77
6100 Chevy Chase Drive Suite 100
Laurel
20707
US-MD
US
1-877-277-6933
U.S. Bank National Association
425 Walnut Street
Cincinnati
45202
1-800-872-2657
Records related to its function as custodian
Brown Brothers Harriman & Co.
50 Post Office Square
Boston
02110
617-772-1818
Records related to its function as custodian and transfer agent
Ultimus Fund Solutions, LLC
225 Pictoria Drive, Suite 450
Cincinnati
45246
631-470-2600
Records related to its function as administrator, transfer agent and accounting agent
N
N
N-1A
7
Y
Thomas T. Sarkany
N/A
N
Joseph Barrato
N/A
Y
Robert S Andrialis
N/A
N
Paul Montgomery
N/A
N
Chris Lewis
N/A
6100 Chevy Chase Drive Suite 100
Laurel
20707
XXXXXX
N
N
N
N
N
N
N
Archer Distributors, LLC
8-68951
000158961
N/A
Y
N
Cohen & Company
925
N/A
Y
N
N
N
N
N
N
Arrow DWA Tactical: International ETF
S000059857
5493008G29ZK0CM7X861
N
1
0
0
Exchange-Traded Fund
N
N
-7.48
-8.18
8.22
8.22
N
N
N
N
N/A
0.00000000
0.00000000
Rule 32a-4 (17 CFR 270.32a-4)
Rule 6c-11 (17 CFR 270.6c-11)
Y
Y
Y
N
Arrow Investment Advisors, LLC
811-22638
000139652
5493000XQEYNVZTQTG53
N
Brown Brothers Harriman & Co.
084-06072
5493006KMX1VFTPYPW14
N
N
N
ICE Data Services
N/A
N
N
Brown Brothers Harriman & Co
5493006KMX1VFTPYPW14
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
Brown Brothers Harriman & Co
5493006KMX1VFTPYPW14
LEI
N
N
N
Ultimus Fund Solutions, LLC
84-05829
Filing Number
N
N
N
Barclays Capital Inc.
8-41342
000019714
AC28XWWI3WIBK2824319
13613.11000000
13613.44000000
Barrington Research Associates, Inc.
8-29831
000013820
549300EAYDU2H358PB45
72392.03734799
Barclays Capital Inc.
8-41342
000019714
AC28XWWI3WIBK2824319
36149.61639699
108541.65374499
N
10259330.37243835
N
N
N
Arrow Managed Futures Strategy Fund
S000035950
549300GGOQ3UXFEQIX49
N
3
0
0
N/A
N
N
N
N/A
0.00000000
0.00000000
Rule 32a-4 (17 CFR 270.32a-4)
N
N
N
N
Arrow Investment Advisors, LLC
811-22638
000139652
5493000XQEYNVZTQTG53
N
Ultimus Fund Solutions, LLC
84-05829
N/A
N
N
N
ICE Data Services
N/A
N
N
U.S. Bank National Association
6BYL5QZYBDK8S7L73M02
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
Ultimus Fund Solutions, LLC
84-05829
Filing Number
N
N
N
Ultimus Fund Solutions, LLC
84-05829
Filing Number
N
N
N
Jonestrading Institutional Services LLC
8-26089
000006888
2138008JJ5PA8H5UIL69
100.00000000
100.00000000
U.S. Bancorp Investments, Inc.
8-35359
000017868
H85Z6XZP8B10ES0M2G89
41200000.03000000
41200000.03000000
N
165588159.11863005
N
N
N
N
Arrow DWA Tactical: Macro Fund
S000035949
549300EHD6B8SNNSS648
N
3
0
0
N/A
N
N
N
N/A
0.00000000
0.00000000
Rule 32a-4 (17 CFR 270.32a-4)
N
N
N
N
Arrow Investment Advisors, LLC
811-22638
000139652
5493000XQEYNVZTQTG53
N
Ultimus Fund Solutions, LLC
84-05829
N/A
N
N
N
ICE Data Services
N/A
N
N
U.S. Bank National Association
6BYL5QZYBDK8S7L73M02
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
Ultimus Fund Solutions, LLC
84-05829
Filing Number
N
N
N
Ultimus Fund Solutions, LLC
84-05829
Filing Number
N
N
N
GTS SECURITIES, LLC
8-68126
000149224
5493005RMIRIL1NTB654
6273.20000000
Barclays Capital Inc.
8-41342
000019714
AC28XWWI3WIBK2824319
21024.54000000
Jonestrading Institutional Services LLC
8-26089
000006888
2138008JJ5PA8H5UIL69
654.09000000
27951.83000000
0.00000000
N
73499158.04978081
N
N
N
N
Arrow Reverse Cap 500 ETF
S000071897
549300SSA5DAEGQYJB47
Y
1
0
0
Exchange-Traded Fund
Y
Y
-0.01
-0.30
2.01
2.01
N
N
N
N
N/A
0.00000000
0.00000000
Rule 32a-4 (17 CFR 270.32a-4)
Rule 6c-11 (17 CFR 270.6c-11)
N
N
N
N
Arrow Investment Advisors, LLC
811-22638
000139652
5493000XQEYNVZTQTG53
N
Brown Brothers Harriman & Co.
084-06072
5493006KMX1VFTPYPW14
N
N
N
ICE Data Services
N/A
N
N
Brown Brothers Harriman & Co
5493006KMX1VFTPYPW14
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
Brown Brothers Harriman & Co
5493006KMX1VFTPYPW14
LEI
N
N
N
Ultimus Fund Solutions, LLC
84-05829
Filing Number
N
N
N
Barclays Capital Inc.
8-41342
000019714
AC28XWWI3WIBK2824319
2395.21999999
2395.21999999
Bank of America Merrill Lynch
8-69787
000283942
549300HN4UKV1E2R3U73
2346587.83000000
Barclays Capital Inc.
8-41342
000019714
AC28XWWI3WIBK2824319
11433.84000000
Goldman Sachs & Co LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
18139098.23484600
20497119.90484599
N
19136981.56383559
N
N
N
Arrow DWA Tactical: Macro ETF
S000041726
549300B11LJJW4DF5P94
N
1
0
0
Exchange-Traded Fund
N
N
N
N
N/A
0.00000000
0.00000000
Rule 6c-11 (17 CFR 270.6c-11)
Rule 32a-4 (17 CFR 270.32a-4)
Y
Y
Y
N
Arrow Investment Advisors, LLC
811-22638
000139652
5493000XQEYNVZTQTG53
N
Brown Brothers Harriman & Co.
084-06072
5493006KMX1VFTPYPW14
N
N
N
ICE Data Services
N/A
N
N
Brown Brothers Harriman & Co
5493006KMX1VFTPYPW14
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
Brown Brothers Harriman & Co
5493006KMX1VFTPYPW14
LEI
N
N
N
Ultimus Fund Solutions, LLC
84-05829
Filing Number
N
N
N
Barclays Capital Inc.
8-41342
000019714
AC28XWWI3WIBK2824319
159.91999999
Barrington Research Associates, Inc.
8-29831
000013820
549300EAYDU2H358PB45
1010.56000000
GTS SECURITIES, LLC
8-68126
000149224
5493005RMIRIL1NTB654
657.28000000
1827.76000000
Goldman Sachs & Co LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
1683908.91984999
1683908.91984999
N
3176821.86627397
N
N
N
Arrow DWA Tactical: Balanced Fund
S000035948
549300SO64CFIGY8X777
N
3
0
0
N/A
N
N
N
N/A
0.00000000
0.00000000
Rule 32a-4 (17 CFR 270.32a-4)
N
N
N
N
Arrow Investment Advisors, LLC
811-22638
000139652
5493000XQEYNVZTQTG53
N
Ultimus Fund Solutions, LLC
84-05829
N/A
N
N
N
ICE Data Services
N/A
N
N
U.S. Bank National Association
6BYL5QZYBDK8S7L73M02
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
Ultimus Fund Solutions, LLC
84-05829
Filing Number
N
N
N
Ultimus Fund Solutions, LLC
84-05829
Filing Number
N
N
N
Jonestrading Institutional Services LLC
8-26089
000006888
2138008JJ5PA8H5UIL69
1153.38000000
GTS SECURITIES, LLC
8-68126
000149224
5493005RMIRIL1NTB654
1135.58000000
Barclays Capital Inc.
8-41342
000019714
AC28XWWI3WIBK2824319
7847.73000000
10136.69000000
Goldman Sachs & Co LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
7645071.26070000
U.S. Bancorp Investments, Inc.
8-35359
000017868
H85Z6XZP8B10ES0M2G89
500000.00272307
Jonestrading Institutional Services LLC
8-26089
000006888
2138008JJ5PA8H5UIL69
3187530.95699999
Barclays Capital Inc.
8-41342
000019714
AC28XWWI3WIBK2824319
60606.16008000
11843208.37994918
N
39689540.39049313
N
N
N
N
Arrow DWA Tactical: International ETF
S000059857
N
50000.00000000
0.00000000
0.00000000
0.00000000
0.00000000
99.90000000
0.00000000
0.10000000
0.00000000
1100.00000000
1100.00000000
0.00000000
1100.00000000
1100.00000000
0.00000000
1100.00000000
1100.00000000
0.00000000
1100.00000000
1100.00000000
0.00000000
N
Arrow Reverse Cap 500 ETF
S000071897
N
50000.00000000
3.20000000
3.60000000
96.80000000
3.60000000
22.50000000
38.90000000
77.50000000
38.90000000
500.00000000
500.00000000
2.00000000
500.00000000
500.00000000
2.00000000
500.00000000
500.00000000
2.00000000
500.00000000
500.00000000
2.00000000
N
Arrow DWA Tactical: Macro ETF
S000041726
N
100000.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
500.00000000
500.00000000
2.00000000
500.00000000
500.00000000
2.00000000
500.00000000
500.00000000
2.00000000
500.00000000
500.00000000
2.00000000
N
true
INTERNAL CONTROL RPT
2
Arrow_DWCR_ETF_ICL.txt
DWCR_7.31.23_N-CEN
REPORT OF INDEPENDENT REGISTERED PUBLIC
ACCOUNTING FIRM
To the Shareholders of Arrow DWA Tactical: International
ETF and the Board of Trustees of Arrow Investments Trust
In planning and performing our audit of the financial
statements of Arrow DWA Tactical: International ETF
(the "Fund"), a series of share of beneficial interest in
Arrow Investments Trust, as of and for the year ended
July 31, 2023, in accordance with the standards of the
Public Company Accounting Oversight Board (United
States) (PCAOB), we considered the Funds 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 Funds 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 funds 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 generally accepted
accounting principles (GAAP). A funds 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 fund; (2) provide reasonable assurance that
transactions are recorded as necessary to permit
preparation of financial statements in accordance with
GAAP, and that receipts and expenditures of the fund
are being made only in accordance with authorizations
of management and Trustees of the fund; and (3)
provide reasonable assurance regarding prevention or
timely detection of unauthorized acquisition, use or
disposition of a funds 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 combination of deficiencies,
in internal control over financial reporting, such that
there is a reasonable possibility that a material
misstatement of the Funds annual or interim financial
statements will not be prevented or detected on a timely
basis.
Our consideration of the Funds 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 PCAOB.
However, we noted no deficiencies in the Funds internal
control over financial reporting and its operation,
including controls over safeguarding securities, that we
consider to be a material weakness as defined above as
of July 31, 2023.
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.
COHEN & COMPANY, LTD.
Philadelphia, Pennsylvania
September 29, 2023
C O H E N & C O M P A N Y , L T D .
800.229.1099 | 866.818.4538 fax | cohencpa.com
Registered with the Public Company Accounting Oversight Board
INTERNAL CONTROL RPT
3
Arrow_DWAT_ETF_ICL.txt
DWAT_7.31.23_N-CEN
REPORT OF INDEPENDENT REGISTERED PUBLIC
ACCOUNTING FIRM
To the Shareholders of Arrow DWA Tactical: Macro ETF
and the Board of Trustees of Arrow Investments Trust
In planning and performing our audit of the financial
statements of Arrow DWA Tactical: Macro ETF (the
"Fund"), a series of shares of beneficial interest in Arrow
Investments Trust, as of and for the year ended July 31,
2023, in accordance with the standards of the Public
Company Accounting Oversight Board (United States)
(PCAOB), we considered the Funds 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 Funds
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 funds 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 generally accepted
accounting principles (GAAP). A funds 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 fund; (2) provide reasonable assurance that
transactions are recorded as necessary to permit
preparation of financial statements in accordance with
GAAP, and that receipts and expenditures of the fund
are being made only in accordance with authorizations
of management and Trustees of the fund; and (3)
provide reasonable assurance regarding prevention or
timely detection of unauthorized acquisition, use or
disposition of a funds 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 combination of deficiencies,
in internal control over financial reporting, such that
there is a reasonable possibility that a material
misstatement of the Funds annual or interim financial
statements will not be prevented or detected on a timely
basis.
Our consideration of the Funds 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 PCAOB.
However, we noted no deficiencies in the Funds internal
control over financial reporting and its operation,
including controls over safeguarding securities, that we
consider to be a material weakness as defined above as
of July 31, 2023.
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.
COHEN & COMPANY, LTD.
Philadelphia, Pennsylvania
September 29, 2023
C O H E N & C O M P A N Y , L T D .
800.229.1099 | 866.818.4538 fax | cohencpa.com
Registered with the Public Company Accounting Oversight Board
INTERNAL CONTROL RPT
4
Arrow_YPS_ETF_ICL.txt
YPS_7.31.23_N-CEN
REPORT OF INDEPENDENT REGISTERED PUBLIC
ACCOUNTING FIRM
To the Shareholders of Arrow Reverse Cap 500 ETF and the
Board of Trustees of Arrow Investments Trust
In planning and performing our audit of the financial
statements of Arrow Reverse Cap 500 ETF (the "Fund"), a
series of shares of beneficial interest in Arrow
Investments Trust, as of and for the year ended July 31,
2023, in accordance with the standards of the Public
Company Accounting Oversight Board (United States)
(PCAOB), we considered the Funds 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 Funds
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 funds 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 generally accepted
accounting principles (GAAP). A funds 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 fund; (2) provide reasonable assurance that
transactions are recorded as necessary to permit
preparation of financial statements in accordance with
GAAP, and that receipts and expenditures of the fund
are being made only in accordance with authorizations
of management and Trustees of the fund; and (3)
provide reasonable assurance regarding prevention or
timely detection of unauthorized acquisition, use or
disposition of a funds 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 combination of deficiencies,
in internal control over financial reporting, such that
there is a reasonable possibility that a material
misstatement of the Funds annual or interim financial
statements will not be prevented or detected on a timely
basis.
Our consideration of the Funds 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 PCAOB.
However, we noted no deficiencies in the Funds internal
control over financial reporting and its operation,
including controls over safeguarding securities, that we
consider to be a material weakness as defined above as
of July 31, 2023.
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.
COHEN & COMPANY, LTD.
Philadelphia, Pennsylvania
September 29, 2023
C O H E N & C O M P A N Y , L T D .
800.229.1099 | 866.818.4538 fax | cohencpa.com
Registered with the Public Company Accounting Oversight Board
INTERNAL CONTROL RPT
5
Arrow_MutualFunds_ICL.txt
ARROW FUNDS_7.31.23_N-CEN
REPORT OF INDEPENDENT REGISTERED PUBLIC
ACCOUNTING FIRM
To the Shareholders of Arrow DWA Tactical: Balanced
Fund, Arrow DWA Tactical: Macro Fund, and Arrow
Managed Futures Strategy Fund and the Board of
Trustees of Arrow Investments Trust
In planning and performing our audits of the
consolidated financial statements of Arrow DWA
Tactical: Balanced Fund, Arrow DWA Tactical: Macro
Fund, and Arrow Managed Futures Strategy Fund (the
"Funds"), each a series of shares of beneficial interest in
Arrow Investments Trust, as of and for the year ended
July 31, 2023, in accordance with the standards of the
Public Company Accounting Oversight Board (United
States) (PCAOB), we considered the Funds 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
Funds internal control over financial reporting.
Accordingly, we express no such opinion.
The management of the Funds 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 funds 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 generally accepted
accounting principles (GAAP). A funds 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 fund; (2) provide reasonable assurance that
transactions are recorded as necessary to permit
preparation of financial statements in accordance with
GAAP, and that receipts and expenditures of the fund
are being made only in accordance with authorizations
of management and Trustees of the fund; and (3)
provide reasonable assurance regarding prevention or
timely detection of unauthorized acquisition, use or
disposition of a funds 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 combination of deficiencies,
in internal control over financial reporting, such that
there is a reasonable possibility that a material
misstatement of the Funds annual or interim financial
statements will not be prevented or detected on a timely
basis.
Our consideration of the Funds 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 PCAOB.
However, we noted no deficiencies in the Funds internal
control over financial reporting and its operation,
including controls over safeguarding securities, that we
consider to be a material weakness as defined above as
of July 31, 2023.
This report is intended solely for the information and use
of management and the Board of Trustees of the Funds
and the Securities and Exchange Commission and is not
intended to be and should not be used by anyone other
than these specified parties.
COHEN & COMPANY, LTD.
Philadelphia, Pennsylvania
September 29, 2023
C O H E N & C O M P A N Y , L T D .
800.229.1099 | 866.818.4538 fax | cohencpa.com
Registered with the Public Company Accounting Oversight Board