Subject: File No. S7-08-15
From: Carol Singer, CPA

June 24, 2015

File No. S7-08-15

Comments on Proposed SEC Rule re: Investment Company Reporting Modernization  (06/2015)

Of the more than 16,000 funds registered with the Commission, I do the accounting, administrative and report preparation functions for one of the smallest funds, a stand-alone registered management investment company that is a closed-end municipal bond fund.  I am very concerned that a number of the proposed changes will place an undue work and financial burden on the fund.

Following are the characteristics of the fund:

1. It is not listed on any exchange.
2. It is a closed-end fund that does not buy or sell its own shares.
3. The fund’s value is under $30,000,000.
4. The fund currently has less than 25 shareholders.
5. The fund invests solely in high-quality municipal bonds and owns less than 100 bonds.
6. The fund generally purchases less than 20 municipal bonds a year.
7. Most bonds are purchased with the intention of holding them to maturity or until called.  The fund rarely sells any bonds in its portfolio.
8. The fund owns no derivatives.
9. The fund does not engage in lending other than through the bonds it purchases.
10. The fund does not enter into any futures contracts.
11. The fund must pay an outside service to prepare its filings with the SEC as it does not have the expertise in house to do the technical set-up and it is probably not cost effective to obtain that expertise.
12. The fund has one very part-time person who performs the accounting, administrative and report preparation functions.

Form N-PORT

Who should file and frequency of filing

I suggest that, while a fund with the characteristics listed above (in particular a fund that is not listed on an exchange, a closed-end fund, a fund of our size and a fund with a limited number of purchases and sales of municipal bonds) should be required to file Form N-PORT, such a fund should not be required to file it monthly.  Quarterly filings would be more appropriate excluding quarter ends when Form N-CSR is to be filed.

Time for filing

It would be most helpful if a fund that is permitted to report quarterly would be permitted at least 45 days to submit is Form N-PORT.  If a fund with characteristics identified above is not granted quarterly reporting, it should be allowed at least 45 days to submit its monthly Form N-PORT.

Disclosures

Some of the new disclosures to be requested on the Form N-PORT should not apply to a fund with the characteristics listed above (in particular a fund that is not listed on an exchange, a closed-end fund, a fund of our size and a fund with limited purchased and sales of municipal bonds).  Such a fund should not be required to provide calculations of duration and spread duration as these are not calculations used by the fund.

LEI (Legal Entity Identifier) number

A fund with these characteristics (in particular a fund that is not listed on an exchange, a closed-end fund, a fund of our size) should not be required to obtain an LEI number as this fund does not need an LEI number for any other purpose.

Other

It is possible that, if the changes requested above are made, other changes that I have not identified should also be made.

Form N-CEN

Annual filings of Form N-CEN seem appropriate.  Allowing 60 days for the filings also seems appropriate.  Some of the requested information will probably be not applicable to a fund with the characteristics listed above.

Conclusion

Your favorable consideration of my comments will be most appreciated.

Submitted by:  Carol Singer, CPA