M&A - 83 Investment Group Income Fund

Form Type: CORRESP

Filing Date: 2024-11-13

Corporate Action: Merger

Type: New

Accession Number: 000158064224006932

Filing Summary: On November 13, 2024, 83 Investment Group Income Fund filed a correspondence regarding its merger plans, detailing the reorganization of an unregistered fund into the Fund through the in-kind purchase of the unregistered fund’s assets. The filing outlined numerous responses to the SEC's comments on the Fund's registration statement, emphasizing that no exemptive relief is required for the merger and that the Fund adheres to the guidelines of the GuidanceStone Letter. The Fund will operate as a shell portfolio at the time of merger, and it has confirmed its compliance with FINRA rules concerning compensation structures due to the nature of its closed-end fund operations. The Fund plans to engage primarily with accredited investors and has revised its disclosure to reflect this limitation, all according to SEC and FINRA regulations. The submission also affirmed the Fund’s approach toward investment strategy, which includes managing distressed or defaulted securities, and highlighted the risks associated with investing in private funds. Furthermore, the correspondence clarified the Fund’s allocation of investment opportunities and mitigation of conflicts of interest.

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