June 29, 2016
VIA EDGAR
Ms. Kimberly Browning
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Re: | Voya Prime Rate Trust |
(SEC File Nos. 333-203624; 811-05410) | |
(SEC File Nos. 333-203653; 811-05410) |
Dear Ms. Browning:
This letter responds to the follow-up comment provided by the Staff of the U.S. Securities and Exchange Commission (“Staff”)on June 29, 2016, for the Registration Statements on Form N-2 of Voya Prime Rate Trust (“Registrant”) filed on April 25, 2016. Our summary of the comment and our response thereto is provided below.
In addition, attached is the requested Tandy Letter (Attachment A).
1. | Comment: The Staff requested that the Registrant represent supplementally how it complies with its fundamental investment policy not to concentrate with respect to investments in asset-backed securities. |
Response: The Registrant represents that, with respect to its fundamental policy on industry concentration, the Adviser uses the Global Industry Classification Standards and Bloomberg L.P. to determine industry classification of securities held by the Registrant, including any asset-backed securities. Specifically, the Adviser will determine the industry classification of asset-backed securities based on the types of assets backing the asset-backed securities (such as, ABS-auto loans, ABS-credit cards, ABS-student loans).
Please feel free to contact me at (617) 235-4636 to discuss any questions or comments you may have regarding the foregoing responses. Thank you for your assistance.
Sincerely,
/s/ Jessica L. Reece
Jessica L. Reece, Esq.
cc: Elizabeth Reza, Esq.
Timothy Diggins, Esq.
Kristen Freeman, Esq.
ATTACHMENT A
VOYA INVESTMENT MANAGEMENT
7337 EAST DOUBLETREE RANCH ROAD, SUITE 100
SCOTTSDALE, AZ 85258
June 29, 2016
VIA EDGAR
Ms. Kimberly Browning
U.S. Securities and Exchange Commission
100 F. Street
Washington, D.C. 20549
RE: | Voya Prime Rate Trust |
(SEC File Nos. 333-203624, 811-05410) | |
(SEC File Nos. 333-203653, 811-05410) |
Dear Ms. Browning:
Voya Prime Rate Trust (the “Registrant”) recognizes the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing. Further, the Registrant recognizes that should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing. Lastly, the Registrant recognizes that it may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please direct any questions or additional comments you may have concerning this letter to the undersigned at 480.477.2666. Thank you.
Regards,
/s/ Huey P. Falgout, Jr. | |
Huey P. Falgout, Jr. | |
Senior Vice President and Chief Counsel | |
Voya Investment Management —Voya Family of Funds |
Attachment
cc: | Elizabeth J. Reza, Esq. |
Ropes & Gray LLP |