3000 Two Logan Square
Eighteenth and Arch Streets
Philadelphia, PA 19103-2799
215.981.4000
Fax 215.981.4750
John P. Falco
direct dial: 215.981.4659
direct fax: 866.422.2114
falcoj@pepperlaw.com
May 30, 2017
Via EDGAR Correspondence
Division of Investment Management
Office of Disclosure and Review
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549
Attn: Megan F. Miller, SEC Accountant
| Re: | Managed Duration Investment Grade Municipal Fund |
Dear Ms. Miller:
On behalf of Managed Duration Investment Grade Municipal Fund (the “Fund”), this letter is being filed with the Securities and Exchange Commission via EDGAR Correspondence to respond to the oral comments of the Commission staff (“Staff”) provided on May 2, 2017, with respect to the Fund’s FormN-CSR filing, including its audited annual report to shareholders, for the fiscal year ended July 31, 2016, in connection with the Staff’s review of periodic disclosures required by Section 408 of Sarbanes-Oxley Act of 2002.
We appreciate the opportunity to address the Staff’s comments. We have organized this letter by setting forth the Staff’s comments in italicized text followed by the Fund’s response to the Staff’s comments.
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1. | The July 31, 2016 annual report to shareholders (the “Annual Report”) indicates that certain fees were waived by the Adviser and Servicing Agent during the period. Please indicate in your response whether such fee waivers are currently in effect, whether such waivers were contractual or voluntary and whether waived amounts can be recouped. If the amounts waived can be recouped please disclose the terms of such recoupment. |
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| | Boston | | Washington, D.C. | | | | Los Angeles | | New York | | Pittsburgh |
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Detroit | | Berwyn | | Harrisburg | | Orange County | | Princeton | | Silicon Valley | | Wilmington |
www.pepperlaw.com
Response: Prior to November 1, 2016, the Adviser and the former Servicing Agent had contractual fee waiver agreements in place. Such fee waiver arrangements did not provide for recoupment of previously waived fees. Effective November 1, 2016, such fee waiver agreements were terminated in connection with the transition of fund administration and shareholder servicing arrangements to a new service provider, which is disclosed in Note 7 of the Notes to the Financial Statements on page 26 of the Annual Report.
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We trust that this response addresses the Staff’s comments.
If you have any further questions, please contact me at 215.981.4659.
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| | Sincerely, | | |
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| | /s/ John P. Falco | | |
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| | John P. Falco | | |
| | Partner | | |
JPF
cc: | Thomas E. Stabile, Treasurer,Insight Select Income Fund |