BNY Mellon Alcentra Global Credit Income 2024 Target Term Fund (DCF)
Filed: 21 Sep 21, 12:00am
 | Proskauer Rose LLP Eleven Times Square New York, NY 10036-8299 |
September 21, 2021
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: John Kernan
| Re: | Funds Listed in Appendix A |
Dear Mr. Kernan:
On behalf of the funds listed in Appendix A hereto (each, a “Fund”), transmitted for filing as EDGAR correspondence are the Funds’ responses to the comments of the accounting staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), provided by you to me and Lisa Goldstein by telephone on August 27, 2021. The Staff’s comments related to (i) the diversification status of certain of the Funds, described in the Funds’ annual reports on Form N-CSR as filed with the Commission and (ii) a Fund’s filings on Form N-MFP with respect of its compliance with Rule 30b1-7 under the Investment Company Act of 1940, as amended (the “1940 Act”).
Set forth below is a summary of the Staff’s comments, and the Funds’ responses thereto.
Diversification Status of Certain Funds
Comment 1: BNY Mellon Global Fixed Income Fund, BNY Mellon Dynamic Total Return Fund and BNY Mellon Global Dynamic Bond Income Fund have been identified in the annual reports as non-diversified funds; however, it appears the funds are operating as diversified funds. If the funds have been operating as diversified funds for more than three years, please confirm that the funds will receive shareholder approval prior to changing their status back to non-diversified.
Response 1: Fund management is aware that these Funds are now de facto diversified and would be required to obtain shareholder approval prior to operating as a “non-diversified company,” if they elected to do so in the future. Fund management will remove the “Non-diversification risk” section and other references to being a non-diversified fund from each of these Funds’ registration statement at the next annual update of the Fund’s registration statement. Each of these Funds will also disclose in the next annual update of its registration statement the following diversification restriction as a fundamental policy: “With respect to 75% of its total assets, purchase securities of an issuer (other than the U.S. Government, its agencies, instrumentalities or authorities or repurchase agreements collateralized by U.S. Government securities and other investment companies), if: (a) such purchase would cause more than 5% of the fund’s total assets taken at market value to be invested in the securities of such issuer; or (b) such purchase would at the time result in more than 10% of the outstanding voting securities of such issuer being held by the fund”.
N-MFP Filings:
Comment 2: The Staff observes that, in N-MFP filings, including the filing coinciding with its fiscal year-end, under Item C.8.h., BNY Mellon Government Money Market Fund appears to have repurchase agreement collateral classified incorrectly. Collateral for a $55 million Bank of Montreal repurchase agreement dated December 31, 2020 due January 4, 2021 was classified as “Agency Debentures and Agency Strips” when “Agency Collateralized Mortgage Obligations” or “Agency Mortgage-Backed Securities” appear to be more appropriate classifications. Please ensure the prospective accuracy of repurchase agreement collateral classifications in Item C.8.h. of Form M-NFP.
Response 2: Going forward, each Fund will ensure the accuracy of its repurchase agreement collateral classifications in Item C.8.h. of Form M-NFP.
* * * * *
Should you have any questions or comments, please feel free to contact me at 212.969.3151 (dkasinki@proskauer.com) or Lisa P. Goldstein at 617.526.9845 (lgoldstein@proskauer.com).
Very truly yours,
/s/ Devin J. Kasinki
Devin J. Kasinki
| cc: | David Stephens |
Lisa P. Goldstein
APPENDIX A
| CIK | File # | Registrant Name | Series ID | Series Name | ||||
| 0000053808 | 811-00524 | BNY Mellon Investment Funds III | S000018029 | BNY Mellon Global Equity Income Fund | ||||
| 0000053808 | 811-00524 | BNY Mellon Investment Funds III | S000005159 | BNY Mellon International Bond Fund | ||||
| 0000053808 | 811-00524 | BNY Mellon Investment Funds III | S000000317 | BNY Mellon High Yield Fund | ||||
| 0000799295 | 811-04813 | BNY Mellon Investment Funds I | S000011353 | BNY Mellon Diversified Emerging Markets Fund | ||||
| 0000799295 | 811-04813 | BNY Mellon Investment Funds I | S000011667 | BNY Mellon Tax Sensitive Total Return Bond Fund | ||||
| 0000799295 | 811-04813 | BNY Mellon Investment Funds I | S000011516 | BNY Mellon Small Cap Value Fund | ||||
| 0000799295 | 811-04813 | BNY Mellon Investment Funds I | S000011515 | BNY Mellon Small Cap Growth Fund | ||||
| 0000799295 | 811-04813 | BNY Mellon Investment Funds I | S000011511 | BNY Mellon International Equity Fund | ||||
| 0000799295 | 811-04813 | BNY Mellon Investment Funds I | S000011502 | BNY Mellon Global Fixed Income Fund | ||||
| 0000799295 | 811-04813 | BNY Mellon Investment Funds I | S000011499 | BNY Mellon Small/Mid Cap Growth Fund | ||||
| 0000810305 | 811-05021 | BNY Mellon Short-Intermediate Municipal Bond Fund | S000000094 | BNY Mellon Short-Intermediate Municipal Bond Fund | ||||
| 0000813383 | 811-05125 | BNY Mellon Variable Investment Fund | S000001924 | Quality Bond Portfolio | ||||
| 0000813383 | 811-05125 | BNY Mellon Variable Investment Fund | S000001923 | Government Money Market Portfolio | ||||
| 0000813383 | 811-05125 | BNY Mellon Variable Investment Fund | S000001921 | International Value Portfolio | ||||
| 0000813383 | 811-05125 | BNY Mellon Variable Investment Fund | S000001920 | International Equity Portfolio | ||||
| 0000813383 | 811-05125 | BNY Mellon Variable Investment Fund | S000001919 | Growth and Income Portfolio | ||||
| 0000813383 | 811-05125 | BNY Mellon Variable Investment Fund | S000001917 | Opportunistic Small Cap Portfolio | ||||
| 0000813383 | 811-05125 | BNY Mellon Variable Investment Fund | S000001912 | Appreciation Portfolio | ||||
| 0000846800 | 811-05719 | BNY Mellon Stock Index Fund, Inc. | S000001911 | BNY Mellon Stock Index Fund, Inc. | ||||
| 0000890064 | 811-07044 | BNY Mellon Sustainable U.S. Equity Portfolio, Inc. | S000001910 | BNY Mellon Sustainable U.S. Equity Portfolio, Inc. | ||||
| 0000914775 | 811-07123 | BNY Mellon Advantage Funds, Inc. | S000059726 | BNY Mellon Sustainable Balanced Fund | ||||
| 0000914775 | 811-07123 | BNY Mellon Advantage Funds, Inc. | S000031204 | BNY Mellon Global Dynamic Bond Income Fund | ||||
| 0000914775 | 811-07123 | BNY Mellon Advantage Funds, Inc. | S000028808 | BNY Mellon Global Real Return Fund | ||||
| 0000914775 | 811-07123 | BNY Mellon Advantage Funds, Inc. | S000011967 | BNY Mellon Dynamic Total Return Fund | ||||
| 0001056707 | 811-08673 | BNY Mellon Investment Portfolios | S000002781 | Technology Growth Portfolio | ||||
| 0001056707 | 811-08673 | BNY Mellon Investment Portfolios | S000002780 | Small Cap Stock Index Portfolio | ||||
| 0001056707 | 811-08673 | BNY Mellon Investment Portfolios | S000002779 | Midcap Stock Portfolio | ||||
| 0001056707 | 811-08673 | BNY Mellon Investment Portfolios | S000002774 | Core Value Portfolio | ||||
| 0001057861 | 811-08703 | BNY Mellon High Yield Strategies Fund | CEF0000589 | BNY Mellon High Yield Strategies Fund | ||||
| 0001627854 | 811-23014 | BNY Mellon Alcentra Global Credit Income 2024 Target Term Fund, Inc. | CEF0001709 | BNY Mellon Alcentra Global Credit Income 2024 Target Term Fund, Inc. | ||||
| 0001635295 | 811-23036 | BNY Mellon Absolute Insight Funds, Inc. | S000059721 | BNY Mellon Core Plus Fund |