Dec. 13, 2022
December 13, 2022 I alone do the work for a very small closed-end registered investment company that is not listed on a securities exchange. While I do not have an issue with filing the Form N-PORT monthly, I do have a significant issue with your proposal to change the due date for such filings from 60 days to 30 days after month end. Whereas the proposed change might not be an issue for me for some months, it would be a significant issue for the months following the Fund's year end and semi-annual reporting periods. During the month after year end, I need to direct my attention to preparing/reviewing documents for the Fund's annual audit, its Form N-CSR, the annual report materials including its proxy documents, the Fund's annual Board meeting and its meeting of its shareholders in addition to the routine daily work required. This proposal will not allow me sufficient time to prepare and file Form N-PORT for the month following its year end. There is a similar workload issue for the month following the semi-annual reporting period. It is unclear to me whether these additional monthly filings will require the Form N-PORT Exhibit F presentation of Regulation S-X compliant portfolio schedules. If so, that will require additional time to prepare these schedules for eight more months of the year. Your favorable consideration to retain the due date for Form N-PORT at 60 days, at least for small reporting entities, will be very much appreciated.