Federated Investors, Inc.
Federated Investors Tower
1001 Liberty Avenue
Pittsburgh, PA 15222-3779
412-288-1900 Phone
FederatedInvestors.com
September 22, 2017
United States Securities and Exchange Commission
Division of Investment Management
3 World Financial Center
New York, N.Y. 10281
Attn: Megan Miller
Dear Ms. Miller:
On August 23, 2017 and September 14, 2017, we discussed comments on various registrants with fiscal period ends from August 31, 2016 to September 30, 2017.
Following are our responses to your comments.
Response: We believe that by disclosing FRSIF’s and FRRBF’s respective investment strategies along with the portfolio of investments, all investments are thereby disclosed to be within those investment strategy parameters, including the investee funds’ investment strategies. If a holding in an investee investment company is material (25% or more) the precise investment objective of the investee is disclosed in the Notes to Financial Statements (NTFS). We disclose the general terms and conditions upon which the investor may redeem investments in investees utilizing the NAV as practical expedient as well as any unique terms and conditions which an investor must satisfy to redeem its investment, as is the case with investments in the Federated Project and Trade Finance Core Fund (FPTFF).
Response: Directors/Trustees fees payable are itemized on the SAL, if any exist at period end, and such expenses are itemized on the SOP. In the NTFS, disclosure indicates that immaterial miscellaneous expenses related to conducting meetings of the Directors/Trustees are included in accrued/miscellaneous expenses. There were no payables to Directors/Trustees at period end.
Response: This was an oversight on the part of the auditor and will be addressed with them.
Response: There were no 17a-7 trades.
Response: Drawdown fees are a type of commitment fee and are received by FPTFF from the borrower in a project or trade financing transaction in which FPTFF participates. . In some cases, the entire amount of the commitment fee is received by FPTFF upon the borrower’s first draw on the facility and are based upon FPTFF’s total commitment, while in other circumstances the fees are received as amounts are drawn against the Facility over time.
Response: In future reports, we will either add the required information to each applicable security description on the Portfolio of Investments (POI) or in an additional schedule in the NTFS.
Response: We will consider disclosure to describe the nature of risk insurance expense in FPTFF’s future filings.
Response: A number of the investee funds are only available to other Federated mutual funds and although the investee funds calculate a daily NAV, that NAV is not published/filed on any site/exchange available to the general public. Because the NAV is not available to the public, these particular investments do not meet the definition of having a readily determinable fair value and therefore, we have determined it appropriate to use NAV as practical expedient for these investee funds.
Response: The Accountant’s Report on Internal Control was erroneously omitted. The filing was amended on 9/14/17.
Response: The dated attribution analysis for FRRBF has recently been removed from the website. It appeared on the site after a deployment error occurred on the website’s server. Federated stopped producing an attribution analysis for FRRBF a number of years ago but when the server deployment error occurred, this dated attribution analysis inadvertently reappeared. System enhancements are underway and Federated is considering controls that might be added in the interim to mitigate the risk of this occurring again. Thank you for bringing this to our attention.
We thank you for your attention to this response letter. If you have any further comments or questions on our responses, please contact me at (412) 288-1277 or Rich Paddock at (412) 288-4479.
Sincerely,
/s/ Lori A. Hensler
Lori A. Hensler
Treasurer
