BlackRock Investment Quality Municipal Trust (BKN)
Filed: 2 Jun 22, 12:00am
| 787 Seventh Avenue New York, NY 10019-6099 Tel: 212 728 8000 Fax: 212 728 8111 | |||
June 2, 2022
VIA EDGAR
David Manion
John Grzeskiewicz
Division of Investment Management
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
| Re: | BlackRock Investment Quality Municipal Trust, Inc. |
(Securities Act File No. 333-263021, Investment Company Act File No. 811-07354)
Response to Staff Comments
Dear Mr. Manion and Mr. Grzeskiewicz:
On behalf of BlackRock Investment Quality Municipal Trust, Inc. (the “Fund”), this letter responds to comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission to the undersigned via telephone on March 14, 2022 and March 25, 2022 regarding the registration statement on Form N-2 (the “Registration Statement”) for the Fund filed on February 25, 2022.
For the convenience of the Staff, the comments are set out below. We have discussed the Staff’s comments with representatives of the Fund. The Fund’s responses to the Staff’s comments are set out immediately under the restated comment. Please note that we have not independently verified information provided by the Fund. The Fund anticipates filing these changes in a Pre-Effective Amendment (the “Amendment”) to the Registration Statement. Unless otherwise indicated, defined terms used herein have the meanings set forth in the Registration Statement and page number references are those of the Registration Statement.
BRUSSELS CHICAGO FRANKFURT HOUSTON LONDON LOS ANGELES MILAN
NEW YORK PALO ALTO PARIS ROME SAN FRANCISCO WASHINGTON
June 2, 2022
Page 2
Accounting Staff Comment
| Comment No. 1: | Statement of Additional Information—Financial Statements. Please correct the reference to the Fund’s semi-annual report such that it reads “. . . the Fund’s semi-annual report to the Fund’s shareholders for the six months ended October 31, 2021 . . . .” (emphasis added). | |
| Response: | The aforementioned reference will be corrected to “the six months ended October 31, 2021” in the Amendment. | |
| Disclosure Staff Comment | ||
| Comment No. 2: | Base Prospectus—Cover Page. Consider adding disclosure that the Fund’s investments that are exempt from federal income tax may be subject to the federal alternative minimum tax. | |
| Response: | The following sentence will be added to the cover page of the Base Prospectus: “As a matter of fundamental policy, under normal market conditions, the Fund will invest at least 80% of its Managed Assets (as defined in this Prospectus) in investments the income from which is exempt from federal income tax (except that the interest may be subject to the federal alternative minimum tax).” | |
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Please do not hesitate to contact me at (212) 728-8955 if you have comments or if you require additional information regarding the Registration Statement.
Respectfully submitted,
/s/ Bissie K. Bonner
Bissie K. Bonner
| cc: | Bomi Lee, Esq., BlackRock, Inc. |
Elliot J. Gluck, Esq., Willkie Farr & Gallagher LLP