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