3000 Two Logan Square
Eighteenth and Arch Streets
Philadelphia, PA 19103-2799
215.981.4000
Fax 215.981.4750
John P. Falco
direct dial: 215.981.4659
direct fax: 866.422.2114
falcoj@pepperlaw.com
September 27, 2017
Via EDGAR
Division of Investment Management
Office of Disclosure and Review
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549
Attn: Christina DiAngelo Fettig, Senior Staff Accountant
Re: | Insight Select Income Fund |
File No. 811-02201 |
Dear Ms. Fettig:
On behalf of Insight Select Income Fund (the “Fund”), this letter responds to the oral comments of the Commission staff (“Staff”) provided on August 28, 2017, with respect to the Fund’s Form N-CSR filing, including its audited annual report to shareholders, for the fiscal year ended March 31, 2017, in connection with the Staff’s review of periodic disclosures required by Section 408 of Sarbanes-Oxley Act of 2002.
We appreciate the opportunity to address the Staff’s comments. We have organized this letter by setting forth the Staff’s comments in italicized text followed by the Fund’s response to the Staff’s comments.
* * *
1. | Confirm that the Fund’s independent registered public accounting firm (“Auditor”) has conducted the required examinations pursuant to Rule 17f-2 during each fiscal year for which such examinations were required and that the required reports were transmitted to the Commission promptly. The Staff view is that “promptly filed” means 30 days from the completion of the examination. |
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Response: The Fund confirms that the required examinations were conducted during each period of the fiscal year for which such examinations were required; however, for certain examinations the transmission of Form 17f-2 to the Commission was not done promptly. The Fund has submitted the required Form 17f-2 filings with the SEC and is adopting procedures to ensure the timely preparation and prompt filing of future Forms 17f-2 with the Commission.
2. | For future filings, please conform the financial highlights table to Form N-CSR and remove “impact for capital share transactions” as a line item. |
Response: Future filings will reflect the Staff’s comment.
* * *
We trust that this response addresses the Staff’s comments. If you have any further questions, please contact the undersigned at 215.981.4659 or in my absence, John M. Ford at (215) 981-4009.
Sincerely, |
/s/ John P. Falco |
John P. Falco |
JPF
cc: | Thomas E. Stabile, Treasurer, Insight Select Income Fund |