Section 16(a) of the Securities Exchange Act of 1934, as
amended (the "1934 Act"), requires the Fund's officers
and Directors, and beneficial owners of more than ten
percent of a registered class of the Fund's equity
securities, to file reports of ownership and changes in
ownership with the SEC and the NYSE. Except as noted
below, to the Fund's knowledge, based solely upon a
review of copies of Forms 3, 4 and 5 and amendments
thereto furnished to the Fund and any written
representations relating thereto, the Fund believes
that its officers and Directors have complied with all
applicable filing requirements for the fiscal year ended
October 31, 2018 with the exception of the late filing
of (i) a Form 3 by Michael Denis, (ii) a Form 3 by Ian
Fitzgerald, (iii) a Form 3 by Blair Jacobson, and (iv) the
purchase by the Adviser of 40,064 Class I Common
Shares and 40,064 Class C Common Shares on July 12,
2017, which were reported to the Commission on
October 10, 2017.



Information Classification: Limited Access

Information Classification: Limited Access