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Gabelli Value 25 Fund

Filed: 11 Mar 21, 12:49pm
X0303

N-CEN: Filer Information

Submission Contact Information

Name
Phone
E-Mail Address

Notification Information

Notify via Filing Website only?Checkbox not checked

N-CEN:Series/Class (Contract) Information

Series ID Record:1
Series ID
S000001076
Class ID Record:1
Class ID
C000034316
Class ID Record:2
Class ID
C000002902
Class ID Record:3
Class ID
C000002904
Class ID Record:4
Class ID
C000088645

N-CEN:Part A: General Information

Item A.1. Reporting period covered.

a. Report for period ending:
2020-12-31
b. Does this report cover a period of less than 12 months?Radio button not checked Yes Radio button checked No

N-CEN:Part B: Information About the Registrant


Item B.1. Background information.

a. Full name of Registrant
Gabelli Value 25 Fund Inc
b. Investment Company Act file number ( e.g., 811-)
811-05848
c. CIK
0000853438
d. LEI
549300RVNFJB7NA2YZ42

Item B.2. Address and telephone number of Registrant.

a. Street 1
One Corporate Center
Street 2
b. City
Rye
c. State, if applicable
NEW YORK
d. Foreign country, if applicable
UNITED STATES OF AMERICA
e. Zip code and zip code extension, or foreign postal code
10580-1422
f. Telephone number (including country code if foreign)
1-800-422-3554
g. Public Website, if any
http://gabelli.com

Item B.3. Location of books and records.

Instruction. Provide the requested information for each person maintaining physical possession of each account, book, or other document required to be maintained by section 31(a) of the Act (15 U.S.C. 80a-30(a)) and the rules under that section.
Location books Record: 1
a. Name of person (e.g., a custodian of records)
The Bank of New York Mellon
b. Street 1
240 Greenwich Street
Street 2
c. City
New York
d. State, if applicable
NEW YORK
e. Foreign country, if applicable
UNITED STATES OF AMERICA
f. Zip code and zip code extension, or foreign postal code
10286
g. Telephone number (including country code if foreign)
1-212-495-1784
h. Briefly describe the books and records kept at this location:
Custody
Location books Record: 2
a. Name of person (e.g., a custodian of records)
BNY Mellon Investment Servicing (US) Inc.
b. Street 1
301 Bellevue Parkway
Street 2
c. City
Wilmington
d. State, if applicable
DELAWARE
e. Foreign country, if applicable
UNITED STATES OF AMERICA
f. Zip code and zip code extension, or foreign postal code
19809
g. Telephone number (including country code if foreign)
1-302-791-1700
h. Briefly describe the books and records kept at this location:
Accounting
Location books Record: 3
a. Name of person (e.g., a custodian of records)
DST Asset Manager Solutions, Inc.
b. Street 1
30 Dan Road
Street 2
c. City
Canton
d. State, if applicable
MASSACHUSETTS
e. Foreign country, if applicable
UNITED STATES OF AMERICA
f. Zip code and zip code extension, or foreign postal code
02021-2809
g. Telephone number (including country code if foreign)
888-772-2337
h. Briefly describe the books and records kept at this location:
Transfer Agent
Location books Record: 4
a. Name of person (e.g., a custodian of records)
Gabelli Funds, LLC
b. Street 1
One Corporate Center
Street 2
c. City
Rye
d. State, if applicable
NEW YORK
e. Foreign country, if applicable
UNITED STATES OF AMERICA
f. Zip code and zip code extension, or foreign postal code
10580-1422
g. Telephone number (including country code if foreign)
914-921-5100
h. Briefly describe the books and records kept at this location:
Accounting

Item B.4. Initial of final filings.

Instruction. Respond "yes" to Item B.4.b only if the Registrant has filed an application to deregister or will file an application to deregister before its next required filing on this form.
a. Is this the first filing on this form by the Registrant? Radio button not checked Yes Radio button checked No
b. Is this the last filing on this form by the Registrant? Radio button not checked Yes Radio button checked No

Item B.5. Family of investment companies.

Instruction. "Family of investment companies" means, except for insurance company separate accounts, any two or more registered investment companies that (i) share the same investment adviser or principal underwriter; and (ii) hold themselves out to investors as related companies for purposes of investment and investor services.In responding to this item, all Registrants in the family of investment companies should report the name of the family of investment companies identically.
Insurance company separate accounts that may not hold themselves out to investors as related companies (products) for purposes of investment and investor services should consider themselves part of the same family if the operational or accounting or control systems under which these entities function are substantially similar.
a. Is the Registrant part of a family of investment companies? Radio button checked Yes Radio button not checked No
i. Full name of family of investment companies
Gabelli/GAMCO Fund Complex

Item B.6. Organization.

Instruction. For Item B.6.a.i., the Registrant should include all Series that have been established by the Registrant and have shares outstanding (other than shares issued in connection with an initial investment to satisfy section 14(a) of the Act).
Indicate the classification of the Registrant by checking the applicable item below.
Checkbox checked a. Open-end management investment company registered under the Act on Form N-1A
Checkbox not checked b. Closed-end management investment company registered under the Act on Form N-2
Checkbox not checked c. Separate account offering variable annuity contracts which is registered under the Act as a management investment company on Form N-3
Checkbox not checked d. Separate account offering variable annuity contracts which is registered under the Act as a unit investment trust on Form N-4
Checkbox not checked e. Small business investment company registered under the Act on Form N-5
Checkbox not checked f. Separate account offering variable insurance contracts which is registered under the Act as a unit investment trust on Form N-6
Checkbox not checked g. Unit investment trust registered under the Act on Form N-8B-2
i. Total number of Series of the Registrant
1

Item B.7. Securities Act registration.

Is the Registrant the issuer of a class of securities registered under the Securities Act of 1933 ("Securities Act")? Radio button checked Yes Radio button not checked No

Item B.8. Directors.

Provide the information requested below about each person serving as director of the Registrant (management investment companies only):
Director Record: 1
a. Full Name
Kuni Nakamura
b. CRD number, if any
N/A
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button not checked Yes Radio button checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
811-23568
File Number Record: 2
File Number Record:
811-22041
File Number Record: 3
File Number Record:
811-02151
File Number Record: 4
File Number Record:
811-04494
File Number Record: 5
File Number Record:
811-04656
File Number Record: 6
File Number Record:
811-04700
File Number Record: 7
File Number Record:
811-04719
File Number Record: 8
File Number Record:
811-05715
File Number Record: 9
File Number Record:
811-06367
File Number Record: 10
File Number Record:
811-07326
File Number Record: 11
File Number Record:
811-07644
File Number Record: 12
File Number Record:
811-08476
File Number Record: 13
File Number Record:
811-09243
File Number Record: 14
File Number Record:
811-09377
File Number Record: 15
File Number Record:
811-09397
File Number Record: 16
File Number Record:
811-21423
File Number Record: 17
File Number Record:
811-21761
File Number Record: 18
File Number Record:
811-22021
File Number Record: 19
File Number Record:
811-22216
File Number Record: 20
File Number Record:
811-22884
File Number Record: 21
File Number Record:
811-23035
File Number Record: 22
File Number Record:
811-23395
Director Record: 2
a. Full Name
Mario J. Gabelli
b. CRD number, if any
000216136
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button checked Yes Radio button not checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
811-04494
File Number Record: 2
File Number Record:
811-02151
File Number Record: 3
File Number Record:
811-04656
File Number Record: 4
File Number Record:
811-04700
File Number Record: 5
File Number Record:
811-04873
File Number Record: 6
File Number Record:
811-05715
File Number Record: 7
File Number Record:
811-06367
File Number Record: 8
File Number Record:
811-06687
File Number Record: 9
File Number Record:
811-07326
File Number Record: 10
File Number Record:
811-07644
File Number Record: 11
File Number Record:
811-07896
File Number Record: 12
File Number Record:
811-08476
File Number Record: 13
File Number Record:
811-08518
File Number Record: 14
File Number Record:
811-08560
File Number Record: 15
File Number Record:
811-09243
File Number Record: 16
File Number Record:
811-09377
File Number Record: 17
File Number Record:
811-09397
File Number Record: 18
File Number Record:
811-21423
File Number Record: 19
File Number Record:
811-21969
File Number Record: 20
File Number Record:
811-22021
File Number Record: 21
File Number Record:
811-22026
File Number Record: 22
File Number Record:
811-22884
File Number Record: 23
File Number Record:
811-23035
File Number Record: 24
File Number Record:
811-23395
Director Record: 3
a. Full Name
Anthony J. Colavita
b. CRD number, if any
N/A
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button not checked Yes Radio button checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
811-22041
File Number Record: 2
File Number Record:
811-04494
File Number Record: 3
File Number Record:
811-06367
File Number Record: 4
File Number Record:
811-06687
File Number Record: 5
File Number Record:
811-07326
File Number Record: 6
File Number Record:
811-07896
File Number Record: 7
File Number Record:
811-08476
File Number Record: 8
File Number Record:
811-08518
File Number Record: 9
File Number Record:
811-08560
File Number Record: 10
File Number Record:
811-09377
File Number Record: 11
File Number Record:
811-09397
File Number Record: 12
File Number Record:
811-21423
Director Record: 4
a. Full Name
Robert J. Morrissey
b. CRD number, if any
N/A
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button not checked Yes Radio button checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
811-06367
File Number Record: 2
File Number Record:
811-04873
File Number Record: 3
File Number Record:
811-09243

Item B.9. Chief compliance officer.

Provide the information requested below about each person serving as chief compliance officer of the Registrant for purposes of rule 38a-1 (17 CFR 270.38a- 1):
Chief compliance officer Record: 1
a. Full Name
Richard J. Walz
b. CRD Number, if any
001392836
c. Street Address 1
One Corporate Center
Street Address 2
d. City
Rye
e. State, if applicable
NEW YORK
f. Foreign country, if applicable
UNITED STATES OF AMERICA
g. Zip code and zip code extension, or foreign postal code
10580
h. Telephone number (including country code if foreign)
XXXXXX
i. Has the chief compliance officer changed since the last filing? Radio button not checked Yes Radio button checked No
If the chief compliance officer is compensated or employed by any person other than the Registrant, or an affiliated person of the Registrant, for providing chief compliance officer services, provide:
CCO employer Record: 1
i. Name of the person
N/A
ii. Person's IRS Employer Identification Number
N/A

Item B.10. Matters for security holder vote.

Instruction. Registrants registered on Forms N-3, N-4 or N-6, should respond "yes" to this Item only if security holder votes were solicited on contract-level matters.
Were any matters submitted by the Registrant for its security holders' vote during the reporting period? Radio button not checked Yes Radio button checked No

Item B.11. Legal proceeding.

Instruction. For purposes of this Item, the following proceedings should be described: (1) any bankruptcy, receivership or similar proceeding with respect to the Registrant or any of its significant subsidiaries; (2) any proceeding to which any director, officer or other affiliated person of the Registrant is a party adverse to the Registrant or any of its subsidiaries; and (3) any proceeding involving the revocation or suspension of the right of the Registrant to sell securities.
a. Have there been any material legal proceedings, other than routine litigation incidental to the business, to which the Registrant or any of its subsidiaries was a party or of which any of their property was the subject during the reporting period? Radio button not checked Yes Radio button checked No
b. Has any proceeding previously reported been terminated? Radio button not checked Yes Radio button checked No

Item B.12. Fidelity bond and insurance (management investment companies only).

a. Were any claims with respect to the Registrant filed under a fidelity bond (including, but not limited to, the fidelity insuring agreement of the bond) during the reporting period? Radio button not checked Yes Radio button checked No

Item B.13. Directors and officers/errors and omissions insurance (management investment companies only).

a. Are the Registrant's officers or directors covered in their capacities as officers or directors under any directors and officers/errors and omissions insurance policy owned by the Registrant or anyone else? Radio button checked Yes Radio button not checked No
i. If yes, were any claims filed under the policy during the reporting period with respect to the Registrant? Radio button not checked Yes Radio button checked No

Item B.14. Provision of financial support.

Instruction. For purposes of this Item, a provision of financial support includes any (1) capital contribution, (2) purchase of a security from a Money Market Fund in reliance on rule 17a-9 under the Act (17 CFR 270.17a-9), (3) purchase of any defaulted or devalued security at fair value reasonably intended to increase or stabilize the value or liquidity of the Registrant's portfolio, (4) execution of letter of credit or letter of indemnity, (5) capital support agreement (whether or not the Registrant ultimately received support), (6) performance guarantee, or (7) other similar action reasonably intended to increase or stabilize the value or liquidity of the Registrant's portfolio. Provision of financial support does not include any (1) routine waiver of fees or reimbursement of Registrant's expenses, (2) routine inter-fund lending, (3) routine inter-fund purchases of Registrant's shares, or (4) action that would qualify as financial support as defined above, that the board of directors has otherwise determined not to be reasonably intended to increase or stabilize the value or liquidity of the Registrant's portfolio.
Did an affiliated person, promoter, or principal underwriter of the Registrant, or an affiliated person of such a person, provide any form of financial support to the Registrant during the reporting period? Radio button not checked Yes Radio button checked No

Item B.15. Exemptive orders.

a. During the reporting period, did the Registrant rely on any orders from the Commission granting an exemption from one or more provisions of the Act, Securities Act or Exchange Act? Radio button not checked Yes Radio button checked No

Item B.16. Principal underwriters.

a. Provide the information requested below about each principal underwriter:
Principal underwriter Record: 1
i. Full name
G.distributors, LLC
ii. SEC file number (e.g., 8-)
008-68697
iii. CRD number
000155071
iv. LEI, if any
N/A
v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Is the principal underwriter an affiliated person of the Registrant, or its investment adviser(s) or depositor? Radio button checked Yes Radio button not checked No
b. Have any principal underwriters been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item B.17. Independent public accountant.

Provide the following information about eachthe independent public accountant:
Public accountant Record: 1
a. Full Name
PricewaterhouseCoopers LLP
b. PCAOB Number
238
c. LEI, if any
5493002GVO7EO8RNNS37
d. State, if applicable
NEW YORK
e. Foreign country, if applicable
UNITED STATES OF AMERICA
f. Has the independent public accountant changed since the last filing?Radio button not checked Yes Radio button checked No

Item B.18. Report on internal control (management investment companies only).

Instruction. Small business investment companies are not required to respond to this item.
For the reporting period, did an independent public accountant's report on internal control note any material weaknesses? Radio button not checked Yes Radio button checked No

Item B.19. Audit opinion.

For the reporting period, did an independent public accountant issue an opinion other than an unqualified opinion with respect to its audit of the Registrant's financial statements? Radio button not checked Yes Radio button checked No

Item B.20. Change in valuation methods.

Instruction. Responses to this item need not include changes to valuation techniques used for individual securities (e.g., changing from market approach to income approach for a private equity security). In responding to Item B.20.c., provide the applicable "asset type" category specified in Item C.4.a. of Form N-PORT. In responding to Item B.20.d., provide a brief description of the type of investments involved. If the change in valuation methods applies only to certain sub-asset types included in the response to Item B.20.c., please provide the sub-asset types in the response to Item B.20.d. The responses to Item B.20.c. and Item B.20.d. should be identical only if the change in valuation methods applies to all assets within that category.
Have there been material changes in the method of valuation (e.g., change from use of bid price to mid price for fixed income securities or change in trigger threshold for use of fair value factors on international equity securities) of the Registrant's assets during the reporting period? Radio button not checked Yes Radio button checked No

Item B.21. Change in accounting principles and practices.

Have there been any changes in accounting principles or practices, or any change in the method of applying any such accounting principles or practices, which will materially affect the financial statements filed or to be filed for the current year with the Commission and which has not been previously reported? Radio button not checked Yes Radio button checked No

Item B.22. Net asset value error corrections (open-end management investment companies only).

a. During the reporting period, were any payments made to shareholders or shareholder accounts reprocessed as a result of an error in calculating the Registrant's net asset value (or net asset value per share)? Radio button not checked Yes Radio button checked No

Item B.23. Rule 19a-1 notice (management investment companies only).

During the reporting period, did the Registrant pay any dividend or make any distribution in the nature of a dividend payment, required to be accompanied by a written statement pursuant to section 19(a) of the Act (15 U.S.C. 80a-19(a)) and rule 19a-1 thereunder (17 CFR 270.19a-1)? Radio button not checked Yes Radio button checked No

N-CEN:Part C: Additional Questions for Management Investment Companies

General Instruction.

Management investment companies that offer multiple series must complete Part C as to each series separately, even if some information is the same for two or more series. To begin this section or add an additional series(s), click on the bar labeled "Add a New Series" below.
Management Investment Record: 1

Item C.1. Background information.

a. Full Name of the Fund

The Gabelli Value 25 Fund Inc.

b. Series identication number, if any

S000001076

c. LEI

549300RVNFJB7NA2YZ42

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

4

b. How many new Classes of shares of the Fund were added during the reporting period?

0

c. How many Classes of shares of the Fund were terminated during the reporting period?

0

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
CLASS I
ii. Class identification number, if any

C000034316

iii. Ticker symbol, if any

GVCIX

Shares Outstanding Record: 2
i. Full name of Class
CLASS A
ii. Class identification number, if any

C000002902

iii. Ticker symbol, if any

GABVX

Shares Outstanding Record: 3
i. Full name of Class
CLASS C
ii. Class identification number, if any

C000002904

iii. Ticker symbol, if any

GVCCX

Shares Outstanding Record: 4
i. Full name of Class
CLASS AAA
ii. Class identification number, if any

C000088645

iii. Ticker symbol, if any

GVCAX


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund
i. Checkbox not checked Exchange-Traded Fund
ii. Checkbox not checked Exchange-Traded Managed Fund
b. Checkbox not checked Index Fund

c. Checkbox not checked Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark
d. Checkbox not checked Interval Fund
e. Checkbox not checked Fund of Funds
f. Checkbox not checked Master-Feeder Fund
g. Checkbox not checked Money Market Fund
h. Checkbox not checked Target Date Fund
i. Checkbox not checked Underlying fund to a variable annuity or variable life insurance contract
Checkbox checked N/A

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked i. Revenue sharing split
Checkbox not checked ii. Non-revenue sharing split (other than administrative fee)
Checkbox not checked iii. Administrative fee
Checkbox not checked iv. Cash collateral reinvestment fee
Checkbox not checked v. Indemnification fee
Checkbox not checked vi. Other
Checkbox checked N/A
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A

g. Provide the net income from securities lending activities

N/A


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked a. Rule 10f-3 (17 CFR 270.10f-3)
Checkbox not checked b. Rule 12d1-1 (17 CFR 270.12d1-1)
Checkbox not checked c. Rule 15a-4 (17 CFR 270.15a-4)
Checkbox not checked d. Rule 17a-6 (17 CFR 270.17a-6)
Checkbox not checked e. Rule 17a-7 (17 CFR 270.17a-7)
Checkbox not checked f. Rule 17a-8 (17 CFR 270.17a-8)
Checkbox checked g. Rule 17e-1 (17 CFR 270.17e-1)
Checkbox not checked h. Rule 22d-1 (17 CFR 270.22d-1)
Checkbox not checked i. Rule 23c-1 (17 CFR 270.23c-1)
Checkbox not checked j. Rule 32a-4 (17 CFR 270.32a-4)
Checkbox not checked N/A

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button checked Yes Radio button not checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Gabelli Funds, LLC
ii. SEC file number ( e.g., 801- )

801-37706

iii.CRD number
000104949
iv. LEI, if any

549300JDTNRQK8NMTG03

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
ii. SEC file number ( e.g., 801- )

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Termination date

c. For each sub-adviser to the Fund, provide the information requested:
i. Full name
ii. SEC file number ( e.g., 801- ), if applicable

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button not checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
ii. SEC file number ( e.g., 801- )

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Termination date


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
DST Asset Manager Solutions, Inc.
ii.SEC file number ( e.g., 84- or 85- )

084-00896

iii. LEI, if any

N/A

iv. State, if applicable
MASSACHUSETTS
v. Foreign country, if applicable
UNITED STATES OF AMERICA
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Intercontinental Exchange, Inc.
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92

Description of other identifying number

iii. State, if applicable
GEORGIA
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
The Bank of New York Mellon
ii. LEI, if any

HPFHU0OQ28E4N0NFVK49

iii. State, if applicable
NEW YORK
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
DST Asset Manager Solutions, Inc.
ii. LEI, if any, or provide and describe other identifying number

084-00896

Description of other identifying number

SEC FILE NUMBER

iii. State, if applicable
MASSACHUSETTS
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
BNY Mellon Investment Servicing (US) Inc.
ii. LEI, if any, or other identifying number

549300CFZQLI9QMJ1Z03

Description of other identifying number

iii. State, if applicable
DELAWARE
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button checked Yes Radio button not checked No
Administrators Record: 2
i. Full name
Gabelli Funds, LLC
ii. LEI, if any, or other identifying number

549300JDTNRQK8NMTG03

Description of other identifying number

iii. State, if applicable
NEW YORK
iv. Foreign country, if applicable
UNITED STATES OF AMERICA
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
G.Research, LLC
b. SEC file number

008-21373

c. CRD number
000007353
d. LEI, if any

N/A

e. State, if applicable
NEW YORK
f. Foreign country, if applicable
UNITED STATES OF AMERICA
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

8886.000000000000

Broker Dealers Record: 2
a. Full name
G.distributors, LLC
b. SEC file number

008-68697

c. CRD number
000155071
d. LEI, if any

N/A

e. State, if applicable
NEW YORK
f. Foreign country, if applicable
UNITED STATES OF AMERICA
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

2482.000000000000


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
STONEX FINANCIAL INC.
ii. SEC file number

008-51269

iii. CRD number
000045993
iv. LEI, if any

549300LNKU6K5TJCRG93

v. State, if applicable
FLORIDA
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

5560.000000000000

Brokers Record: 2
i. Full name of broker
MKM PARTNERS LLC
ii. SEC file number

008-53436

iii. CRD number
000114666
iv. LEI, if any

25490041O5W104HFWA62

v. State, if applicable
CONNECTICUT
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

4570.000000000000

Brokers Record: 3
i. Full name of broker
G.RESEARCH, LLC
ii. SEC file number

008-21373

iii. CRD number
000007353
iv. LEI, if any

N/A

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

8886.000000000000

Brokers Record: 4
i. Full name of broker
CREDIT SUISSE SECURITIES (USA) LLC
ii. SEC file number

008-00422

iii. CRD number
000000816
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

3390.000000000000

Brokers Record: 5
i. Full name of broker
Cowen and Company, LLC
ii. SEC file number

008-22522

iii. CRD number
000007616
iv. LEI, if any

549300WR155U7DVMIW58

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

4520.000000000000

Brokers Record: 6
i. Full name of broker
SANFORD C. BERNSTEIN & CO., LLC
ii. SEC file number

008-52942

iii. CRD number
000104474
iv. LEI, if any

549300I7JYZHT7D5CO04

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

4039.000000000000

Brokers Record: 7
i. Full name of broker
MORGAN STANLEY & CO. LLC
ii. SEC file number

008-15869

iii. CRD number
000008209
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

2880.000000000000

Brokers Record: 8
i. Full name of broker
CANTOR FITZGERALD & CO.
ii. SEC file number

008-00201

iii. CRD number
000000134
iv. LEI, if any

5493004J7H4GCPG6OB62

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

4867.000000000000

Brokers Record: 9
i. Full name of broker
UBS Securities LLC
ii. SEC file number

008-22651

iii. CRD number
000007654
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

3946.000000000000

Brokers Record: 10
i. Full name of broker
J.P. Morgan Securities LLC
ii. SEC file number

008-35008

iii. CRD number
000000079
iv. LEI, if any

ZBUT11V806EZRVTWT807

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Gross commissions paid by the Fund for the reporting period

3330.000000000000

b. Aggregate brokerage commissions paid by Fund during the reporting period:

59126.000000000000


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
Daiwa Capital Markets America, Inc.
ii. SEC file number

008-12242

iii. CRD number
000001576
iv. LEI, if any

M67H5PRC0NQKM73ZAS82

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

1059740.000000000000

Principal Transactions Record: 2
i. Full name of dealer
ROLLS-ROYCE HOLDINGS PLC
ii. SEC file number

N/A

iii. CRD number
N/A
iv. LEI, if any

213800EC7997ZBLZJH69

v. State, if applicable
vi. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

7264.000000000000

Principal Transactions Record: 3
i. Full name of dealer
RBC CAPITAL MARKETS LLC
ii. SEC file number

008-45411

iii. CRD number
000031194
iv. LEI, if any

549300LCO2FLSSVFFR64

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

14079478.000000000000

Principal Transactions Record: 4
i. Full name of dealer
NOMURA SECURITIES INTERNATIONAL, INC.
ii. SEC file number

008-15255

iii. CRD number
000004297
iv. LEI, if any

OXTKY6Q8X53C9ILVV871

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

26454959.000000000000

Principal Transactions Record: 5
i. Full name of dealer
BMO CAPITAL MARKETS CORP.
ii. SEC file number

008-34344

iii. CRD number
000016686
iv. LEI, if any

RUC0QBLBRPRCU4W1NE59

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

1964015.000000000000

Principal Transactions Record: 6
i. Full name of dealer
BARCLAYS CAPITAL, INC.
ii. SEC file number

008-41342

iii. CRD number
000019714
iv. LEI, if any

AC28XWWI3WIBK2824319

v. State, if applicable
NEW YORK
vi. Foreign country, if applicable
UNITED STATES OF AMERICA
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

15296550.000000000000

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

58862006.000000000000


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button checked Yes Radio button not checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

287685581.000000000000

b. Provide the money market fund's daily average net assets during the reporting period

0.000000000000


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No

N-CEN:Part E: Additional Questions for Exchange-Traded Funds and Exchange-Traded Managed Funds

N-CEN:Part G: Attachments

Item G.1a. Attachments.

Attachments applicable to all Registrants. All Registrants shall file the following attachments, as applicable, with the current report. Indicate the attachments filed with the current report by checking the applicable items below: Checkbox not checked i. Legal proceedings
Checkbox not checked ii. Provision of financial support
Checkbox checked iii. Independent public accountant's report on internal control (management investment companies other than small business investment companies only)
Checkbox not checked iv. Change in accounting principles and practices
Checkbox not checked v. Information required to be filed pursuant to exemptive orders
Checkbox not checked vi. Other information required to be included as an attachment pursuant to Commission rules and regulations

Instructions.

1. Item G.1.a.i. Legal proceedings.

(a) If the Registrant responded "YES" to Item B.11.a., provide a brief description of the proceedings. As part of the description, provide the case or docket number (if any), and the full names of the principal parties to the proceeding.
(b) If the Registrant responded "YES" to Item B.11.b., identify the proceeding and give its date of termination.

2. Item G.1.a.ii. Provision of financial support. If the Registrant responded "YES" to Item B.14., provide the following information (unless the Registrant is a Money Market Fund): (a) Description of nature of support.

(b) Person providing support.

(c) Brief description of relationship between the person providing support and the Registrant.

(d) Date support provided.

(e) Amount of support.

(f) Security supported (if applicable). Disclose the full name of the issuer, the title of the issue (including coupon or yield, if applicable) and at least two identifiers, if available (e.g., CIK, CUSIP, ISIN, LEI).
(g) Value of security supported on date support was initiated (if applicable).

(h) Brief description of reason for support.

(i) Term of support.

(j) Brief description of any contractual restrictions relating to support.

3. Item G.1.a.iii. Independent public accountant's report on internal control (management investment companies other than small business investment companies only). Each management investment company shall furnish a report of its independent public accountant on the company's system of internal accounting controls. The accountant's report shall be based on the review, study and evaluation of the accounting system, internal accounting controls, and procedures for safeguarding securities made during the audit of the financial statements for the reporting period. The report should disclose any material weaknesses in: (a) the accounting system; (b) system of internal accounting control; or (c) procedures for safeguarding securities which exist as of the end of the Registrant's fiscal year.

The accountant's report shall be furnished as an exhibit to the form and shall: (1) be addressed to the Registrant's shareholders and board of directors; (2) be dated; (3) be signed manually; and (4) indicate the city and state where issued.

Attachments that include a report that discloses a material weakness should include an indication by the Registrant of any corrective action taken or proposed.

The fact that an accountant's report is attached to this form shall not be regarded as acknowledging any review of this form by the independent public accountant.

4. Item G.1.a.iv. Change in accounting principles and practices. If the Registrant responded "YES" to Item B.21, provide an attachment that describes the change in accounting principles or practices, or the change in the method of applying any such accounting principles or practices. State the date of the change and the reasons therefor. A letter from the Registrant's independent accountants, approving or otherwise commenting on the change, shall accompany the description.

5. Item G.1.a.v. Information required to be filed pursuant to exemptive orders. File as an attachment any information required to be reported on Form N-CEN or any predecessor form to Form N-CEN (e.g., Form N-SAR) pursuant to exemptive orders issued by the Commission and relied on by the Registrant.

6. Item G.1.a.vi. Other information required to be included as an attachment pursuant to Commission rules and regulations. File as an attachment any other information required to be included as an attachment pursuant to Commission rules and regulations.

N-CEN: Signature

Pursuant to the requirements of the Investment Company Act of 1940, the Registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
Registrant
Gabelli Value 25 Fund Inc
Date
2021-03-11
Signature
John C. Ball
Title
Treasurer