0001752724-22-175385.txt : 20220812
0001752724-22-175385.hdr.sgml : 20220812
20220812155709
ACCESSION NUMBER: 0001752724-22-175385
CONFORMED SUBMISSION TYPE: N-CEN
PUBLIC DOCUMENT COUNT: 4
CONFORMED PERIOD OF REPORT: 20220531
FILED AS OF DATE: 20220812
DATE AS OF CHANGE: 20220812
EFFECTIVENESS DATE: 20220812
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Northern Lights Fund Trust IV
CENTRAL INDEX KEY: 0001644419
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FISCAL YEAR END: 0916
FILING VALUES:
FORM TYPE: N-CEN
SEC ACT: 1940 Act
SEC FILE NUMBER: 811-23066
FILM NUMBER: 221159804
BUSINESS ADDRESS:
STREET 1: 225 PICTORIA DRIVE
STREET 2: SUITE 450
CITY: CINCINNATI
STATE: OH
ZIP: 45246
BUSINESS PHONE: 402-895-1600
MAIL ADDRESS:
STREET 1: 17605 WRIGHT STREET
STREET 2: SUITE 200
CITY: OMAHA
STATE: NE
ZIP: 68154-1150
0001644419
S000054990
LGM Risk Managed Total Return Fund
C000172959
LGM Risk Managed Total Return Fund Institutional Class
LBETX
0001644419
S000056066
Formula Folios Hedged Growth ETF
C000176629
Formula Folios Hedged Growth ETF
FFHG
0001644419
S000056067
FormulaFolios Tactical Income ETF
C000176630
FormulaFolios Tactical Income ETF
FFTI
0001644419
S000059209
FormulaFolios Smart Growth ETF
C000194007
FormulaFolios Smart Growth ETF
FFSG
0001644419
S000059210
FormulaFolios Tactical Growth ETF
C000194008
FormulaFolios Tactical Growth ETF
FFTG
0001644419
S000068966
Sterling Capital Focus Equity ETF
C000220403
Sterling Capital Focus Equity ETF
LCG
0001644419
S000074383
Sterling Capital Diverse Multi-Manager Active ETF
C000232235
Sterling Capital Diverse Multi-Manager Active ETF
DEIF
N-CEN
1
primary_doc.xml
X0404
N-CEN
LIVE
0001644419
XXXXXXXX
811-23066
true
false
false
N-1A
S000074383
C000232235
S000068966
true
S000054990
C000172959
S000056066
C000176629
S000056067
true
S000059209
true
S000059210
true
Northern Lights Fund Trust IV
811-23066
0001644419
549300UIBIHXQ3PDEC28
225 Pictoria Drive
Suite 450
Cincinatti
45246
US-OH
US
631-470-2603
Ultimus Fund Solutions, LLC.
4221 N. 203rd Street
Suite 100
Elkhorn
68022
631-470-2600
Records related to its function as administrator, Transfer agent records and accounting agent
N
N
N
N-1A
30
Y
Thomas Sarkany
N/A
N
Charles Ranson
N/A
N
Joseph Breslin
N/A
N
James Ash
N/A
4221 North 203rd Street
Suite 100
Elkhorn
68022
XXXXXX
N
N
N
N
N
N
N
Northern Lights Distributors, LLC
8-065857
000126159
N/A
Y
N
Cohen & Co.
925
N/A
N
N
N
N
N
N
N
Sterling Capital Diverse Multi-Manager Active ETF
S000074383
549300TO0JLIBEBANY11
Y
1
0
0
Exchange-Traded Fund
Y
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
Sterling Capital Management LLC
801-64257
000135405
549300H8QJNF9O127E84
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
Filling Number
N
N
N
SUSQUEHANNA CAPITAL GROUP
8-43174
000029337
5493003MWY2FX7868J26
27662.00000000
27662.00000000
BANK OF AMERICA MERRILL LYNCH
8-69787
000283942
549300HN4UKV1E2R3U73
96479075.00000000
96479075.00000000
N
99207359.00000000
N
N
N
Sterling Capital Focus Equity ETF
S000068966
549300TQVFTFHODA5C95
N
1
0
0
Exchange-Traded Fund
Y
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
Sterling Capital Management LLC
801-64257
000135405
549300H8QJNF9O127E84
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
Fililng Number
N
N
N
SUSQUEHANNA CAPITAL GROUP
8-43174
000029337
5493003MWY2FX7868J26
3397.00000000
3397.00000000
VIRTU FINANCIAL
8-51262
000045986
5493006FX0HRYU3G2R47
19922951.00000000
BANK OF AMERICA MERRILL LYNCH
8-69787
000283942
549300HN4UKV1E2R3U73
36478428.00000000
56401379.00000000
N
44739660.00000000
N
N
N
LGM Risk Managed Total Return Fund
S000054990
549300N2LKIUKPGU2W67
N
1
0
1
Fund of Funds
N
N
N
N
N/A
0.00000000
0.00000000
Rule 32a-4 (17 CFR 270.32a-4)
N
N
N
N
LGM Capital Management, LLC
801-108408
N/A
N/A
N
Ultimus Fund Solutions, LLC
84-05829
N/A
N
N
N
ICE Data Services
N/A
N
N
Huntington Bancshares, inc.
549300XTVCVV917B5T19
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
Wallabeth
8-67936
000147853
549300R371KUKXEXC133
6890.14000000
Huntington Bank
8-34867
000016986
2WHM8VNJH63UN14OL754
200.00000000
7090.14000000
0.00000000
N
17057064.63161643
0.00000000
N
N
N
N
FormulaFolios Hedged Growth ETF
S000056066
549300ICK5K6VJP3JT55
N
1
0
0
Exchange-Traded Fund
Fund of Funds
N
N
Y
N
N
Securities Finance Trust Company
549300TG9E1QX4XYSB91
N
N
N/A
2032177.26
2638.00000000
Rule 6c-11 (17 CFR 270.6c-11)
Rule 32a-4 (17 CFR 270.32a-4)
Y
Y
Y
N
FormulaFolios Investments, LLC
801-72780
000153467
N/A
N
Brown Brothers Harriman & Co
N/A
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
8-69731
Filing Number
N
N
N
Ultimus Fund Solutions, LLC.
84-05829
Filing Number
N
N
N
Virtu Financial
8-51262
000045986
5493006FX0HRYU3G2R47
6272.88000000
6272.88000000
Citadel Securities LLC
008-53574
000116797
12UUJYTN7D3SW8KCSG25
3476380.32000000
Virtu Financial
8-51262
000045986
5493006FX0HRYU3G2R47
12136919.05961499
Bank of America Merrill Lynch
8-7221
000007691
8NAV47T0Y26Q87Y0QP81
1550475.21000000
17163774.58961499
N
43148837.45342467
N
N
N
FormulaFolios Tactical Income ETF
S000056067
549300HTILRNDV1GFV35
N
1
0
0
Exchange-Traded Fund
Fund of Funds
N
N
Y
N
N
Securities Finance Trust Company
549300TG9E1QX4XYSB91
N
N
N/A
70925459.55
578893.00000000
Rule 32a-4 (17 CFR 270.32a-4)
Rule 6c-11 (17 CFR 270.6c-11)
Y
N
N
N
FormulaFolios Investments, LLC
801-72780
000153467
N/A
N
Brown Brothers Harriman & Co
N/A
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
8-69731
Filing Number
N
N
N
Ultimus Fund Solutions, LLC.
84-05829
Filing Number
N
N
N
Virtu Financial
8-51262
000045986
5493006FX0HRYU3G2R47
34368.63999999
34368.63999999
Goldman, Sachs & Co. LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
1185154.40999999
Virtu Financial
8-51262
000045986
5493006FX0HRYU3G2R47
2093539.10000000
Bank of America Merrill Lynch
8-7221
000007691
8NAV47T0Y26Q87Y0QP81
29695853.05000000
J.P. Morgan Securities LLC
8-35008
000000079
ZBUT11V806EZRVTWT807
46911968.20140799
Citadel Securities LLC
008-53574
000116797
12UUJYTN7D3SW8KCSG25
8033063.87999999
87919578.64140799
N
210555243
N
N
N
FormulaFolios Smart Growth ETF
S000059209
549300IMXOYJC1K25N10
N
1
0
0
Exchange-Traded Fund
Fund of Funds
N
N
Y
N
N
Securities Finance Trust Company
549300TG9E1QX4XYSB91
N
N
N/A
2183299.15
274.00000000
Rule 6c-11 (17 CFR 270.6c-11)
Rule 32a-4 (17 CFR 270.32a-4)
Y
Y
Y
N
FormulaFolios Investments, LLC
801-72780
000153467
N/A
N
Brown Brothers Harriman & Co.
N/A
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
8-69731
Filing Number
N
N
N
Ultimus Fund Solutions, LLC.
84-05829
Filing Number
N
N
N
Virtu Financial
8-51262
000045986
5493006FX0HRYU3G2R47
3136.02000000
3136.02000000
Citadel Securities LLC
008-53574
000116797
12UUJYTN7D3SW8KCSG25
1466666.36000000
Virtu Financial
8-51262
000045986
5493006FX0HRYU3G2R47
8495143.56000000
Bank of America Merrill Lynch
8-7221
000007691
8NAV47T0Y26Q87Y0QP81
934356.70000000
Goldman, Sachs & Co. LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
1799925.54000000
12696092.16000000
N
41493194.90827400
N
N
N
FormulaFolios Tactical Growth ETF
S000059210
549300QNAMBTMFIBOZ57
N
1
0
0
Exchange-Traded Fund
Fund of Funds
N
N
Y
N
N
Securities Finance Trust Company
549300TG9E1QX4XYSB91
N
N
N/A
5052209.75
4214.00000000
Rule 6c-11 (17 CFR 270.6c-11)
Rule 32a-4 (17 CFR 270.32a-4)
Y
Y
Y
N
FormulaFolios Investments, LLC
801-72780
000153467
N/A
N
Brown Brothers Harriman & Co
N/A
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
8-69731
Filing Number
N
N
N
Ultimus Fund Solutions, LLC.
84-05829
Filing Number
N
N
N
BROWN BROTHERS & HARRIMAN
8-69731
000282732
5493006KMX1VFTPYPW14
1458.12000000
Virtu Financial
8-51262
000045986
5493006FX0HRYU3G2R47
5959.25000000
7417.37000000
Citadel Securities LLC
008-53574
000116797
12UUJYTN7D3SW8KCSG25
3780990.28842499
Virtu Financial
8-51262
000045986
5493006FX0HRYU3G2R47
6825636.73000000
Bank of America Merrill Lynch
8-7221
000007691
8NAV47T0Y26Q87Y0QP81
1341089.89999999
Goldman, Sachs & Co. LLC
8-129
000000361
FOR8UP27PHTHYVLBNG30
2957839.14000000
14905556.05842500
N
46696352.79624658
N
N
N
Sterling Capital Diverse Multi-Manager Active ETF
S000074383
N
25000.00000000
3.06000000
0.00000000
96.94000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
500.00000000
500.00000000
2.00000000
500.00000000
500.00000000
2.00000000
0.00000000
500.00000000
2.00000000
0.00000000
500.00000000
2.00000000
N
Sterling Capital Focus Equity ETF
S000068966
N
25000.00000000
0.59000000
0.00000000
99.41000000
0.00000000
0.68000000
0.00000000
99.32000000
0.00000000
250.00000000
250.00000000
2.00000000
250.00000000
250.00000000
2.00000000
0.00000000
250.00000000
2.00000000
0.00000000
250.00000000
2.00000000
N
FormulaFolios Hedged Growth ETF
S000056066
N
50000.00000000
0.00000000
0.00000000
0.00000000
0.00000000
1.56000000
0.00000000
98.44000000
0.00000000
250.00000000
250.00000000
2.00000000
250.00000000
250.00000000
2.00000000
0
250.00000000
2.00000000
0
250.00000000
2.00000000
Y
FormulaFolios Tactical Income ETF
S000056067
N
50000.00000000
1.37000000
0.00000000
98.63000000
0.00000000
1.65000000
0.00000000
98.35000000
0.00000000
250.00000000
250.00000000
2.00000000
250.00000000
250.00000000
2.00000000
0
250.00000000
2.00000000
0
250.00000000
2.00000000
Y
FormulaFolios Smart Growth ETF
S000059209
N
25000.00000000
0.00000000
0.00000000
0.00000000
0.00000000
9.69000000
0.00000000
90.31000000
0.00000000
250.00000000
250.00000000
2.00000000
250.00000000
250.00000000
2.00000000
0
250.00000000
2.00000000
0
250.00000000
2.00000000
Y
FormulaFolios Tactical Growth ETF
S000059210
N
25000.00000000
0.00000000
0.00000000
0.00000000
0.00000000
1.45000000
0.00000000
98.55000000
0.00000000
250.00000000
250.00000000
2.00000000
250.00000000
250.00000000
2.00000000
0
250.00000000
2.00000000
0
250.00000000
2.00000000
Y
true
INTERNAL CONTROL RPT
2
iclettersterling.txt
IC LETTER STERLING ETFS
REPORT OF INDEPENDENT REGISTERED PUBLIC
ACCOUNTING FIRM
To the Shareholders of Sterling Capital Focus Equity ETF,
Sterling Capital Diverse Multi-Manager Active ETF and
Board of Trustees of Northern Lights Fund Trust IV
In planning and performing our audit of the financial
statements of Sterling Capital Focus Equity ETF and Sterling
Capital Diverse Multi-Manager Active ETF (the Funds), each a
series of Northern Lights Fund Trust IV, as of and for the year
or period ended May 31, 2022, 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 May 31, 2022.
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.
/s/COHEN & COMPANY, LTD.
Milwaukee, Wisconsin
July 29, 2022
INTERNAL CONTROL RPT
3
IC_Letter_FormulaFolios_ETFs.txt
IC LETTER FF ETFS
REPORT OF INDEPENDENT REGISTERED PUBLIC
ACCOUNTING FIRM
To the Shareholders of FormulaFolios Hedged Growth ETF,
FormulaFolios Smart Growth ETF, FormulaFolios Tactical
Growth ETF, and FormulaFolios Tactical Income ETF and
Board of Trustees of Northern Lights Fund Trust IV
In planning and performing our audit of the financial
statements of FormulaFolios Hedged Growth ETF,
FormulaFolios Smart Growth ETF, FormulaFolios Tactical
Growth ETF, and FormulaFolios Tactical Income ETF (the
"Funds"), each a series of Northern Lights Fund Trust IV, as of
and for the year ended May 31, 2022, 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 May 31, 2022.
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.
Milwaukee, Wisconsin
July 29, 2022
INTERNAL CONTROL RPT
4
NCENLGMLetter.txt
LGM IC LETTER
REPORT OF INDEPENDENT REGISTERED PUBLIC
ACCOUNTING FIRM
To the Shareholders of LGM Risk Managed Total Return Fund and
Board of Trustees of Northern Lights Fund Trust IV
In planning and performing our audit of the financial statements
of LGM Risk Managed Total Return Fund (the Fund), a series of
Northern Lights Fund Trust IV, as of and for the year ended May
31, 2022, 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 May 31, 2022.
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.
Milwaukee, Wisconsin
July 29, 2022