COMMENTS RECEIVED ON 02/18/2020
FROM EDWARD BARTZ
FIDELITY CENTRAL INVESTMENT PORTFOLIOS LLC (File No. 811-21667)
Fidelity High Income Central Fund
AMENDMENT NO. 55
1)
“Investment Details” (prospectus)
“Principal Investment Strategies”
C:
The Staff requests we disclose the maturity policy for the fund’s debt securities.
R:
The fund does not have a principal investment strategy of investing in securities with a particular maturity. Accordingly, we have not modified disclosure.
2)
“Investment Details” (prospectus)
“Principal Investment Strategies”
C:
The Staff requests we explain whether there are any investments in contingent convertible securities
and, if so, include appropriate strategy and risk disclosure.
R:
Investing in contingent convertible securities is not a principal investment strategy for the fund.
Accordingly, we have not modified the disclosure.
3)
“Investment Details” (prospectus)
“Principal Investment Strategies”
C:
The Staff questions whether the fund will invest in emerging markets securities and, if so, asks that we include appropriate strategy and risk disclosure.
R:
Although the fund may invest in securities of foreign issuers, including emerging markets securities, investments in emerging markets are not a principal investment strategy of the fund. As a result, the fund believes that the current strategy and risk disclosure is appropriate.
4)
“Investment Details” (prospectus)
“Principal Investment Risks”
C:
Since the fund’s principal investment strategy states that the fund emphasizes junk bonds, the Staff requests we add a separate junk bond risk for lower-quality securities.
R:
We believe the risks associated with investing in junk bonds are described in “Issuer−Specific Changes” and, therefore, the addition of a separate risk factor for this type of investment would be duplicative.
