Item
7. Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.
The Proxy Voting Policies are attached
herewith.
Eagle Growth And Income
Opportunities Fund
PROXY VOTING POLICIES
AND PROCEDURES
It is the policy of the Board
of Trustees (the “Board”) of Eagle Growth and Income Opportunities Fund (the “Fund”) to delegate the responsibility
for voting proxies relating to the securities held by the Fund to the Fund’s Adviser (the “Adviser”) and Subadviser
(the “Subadviser”), subject to the Board’s continuing oversight. The Board hereby delegates such responsibility
to the Fund’s Adviser and Subadviser, and directs the Adviser and Subadviser to vote proxies relating to Fund portfolio securities
managed by the Adviser and Subadviser, respectively, consistent with the duties and procedures set forth below. The Adviser and
Subadviser may retain a third party to review, monitor and recommend how to vote proxies in a manner consistent with the duties
and procedures set forth below, to ensure such proxies are voted on a timely basis and to provide reporting and/or record retention
services in connection with proxy voting for the Fund.
The right to vote a proxy
with respect to securities held by the Fund is an asset to the Fund. The Adviser and Subadviser, to which authority to vote on
behalf of the Fund is delegated, acts as a fiduciary of the Fund and must vote proxies in a matter consistent with the best interest
of the Fund and its shareholders. In discharging this fiduciary duty, the Advise r an d Subadviser must maintain and adhere to
its policies and procedures for addressing conflicts of interest and must vote in a manner substantially consistent with its policies,
procedures and guidelines,
as presented to the Board.
The following are the procedures adopted by the Board
for the administration of this policy:
|
A.
|
Review of Subadviser’s Proxy Voting Procedures.
The Adviser and Subadviser shall present to the Board their policies, procedures and other guidelines for voting proxies
at least annually, and must notify the Board promptly of material changes to any of these documents, including changes to policies
and procedures addressing conflicts of interest.
|
|
B.
|
Voting Record Reporting. The Adviser
and Subadviser shall ensure that the voting record necessary for the completion and filing of Form N-PX is provided to the Fund’s
administrator at least annually. Such voting record information shall be in a form acceptable to the Fund and shall be provided
at such time(s) as are required for the timely filing of Form N-PX and at such additional times(s) as the Fund and the Adviser
or the Subadviser, as applicable, may agree from time to time. With respect to those proxies that the Adviser or Subadviser, as
applicable, has identified as involving a conflict of interest, the Adviser or Subadviser shall submit a report indicating the
nature of the conflict of interest and how that conflict was resolved with respect to the voting of the proxy.
|
|
C.
|
Conflicts of Interest. Any actual or
potential conflicts of interest between the Adviser or Subadviser, on the one hand, and the Fund's shareholders, on the other
hand, arising from the proxy voting process will be addressed by the Adviser or Subadviser, as applicable, and the Adviser’s
or Subadviser’s application of its proxy voting procedures pursuant to the delegation of proxy voting responsibilities to
the Adviser and Subadviser. In the event that the Adviser or Subadviser notifies the Chief Compliance Officer of the Fund (the
“CCO”) that a conflict of interest cannot be resolved under the applicable Proxy Voting Procedures, the CCO is responsible
for notifying the Chairman of the Board of the Fund of the irreconcilable conflict of interest and assisting the Chairman with
any actions he determines are necessary.
|
A “conflict of interest”
includes, for example, any circumstance when the Fund, the Adviser, the Subadviser or one or more of their affiliates (including
officers, directors and employees) knowingly does business with, receives compensation from, or sits on the board of, a particular
issuer or closely affiliated entity, and therefore, may appear to have a conflict of interest between its own interests and the
interests of Fund shareholders in how proxies of that issuer are voted. Situations where the issuer seeking the proxy vote is also
a client of the Adviser or Subadviser, as applicable, are deemed to be potential conflicts of interest. Potential conflicts of
interest may also arise in connection with consent solicitations relating to debt securities where the issuer of debt is also a
client of the Adviser or Subadviser, as applicable.
|
D.
|
Securities Lending Program. When the
Fund’s securities are out on loan, they are transferred into the borrower’s name and are voted by the borrower, in
its discretion. Where the Adviser or Subadviser determines, however, that there is a proxy vote (or other shareholder action)
for a material event, the Adviser or Subadviser, as applicable, should request that the agent recall the security prior to the
record date to allow the A dv i s e r or Subadviser to vote the proxy for the security. When determining whether to recall securities
to allow for a proxy vote, the Adviser or Subadviser will determine whether such action is beneficial to the Fund and its shareholders
by considering the materiality of the proxy item, the percentage of the issuer’s shares held, the likelihood of materially
affecting the proxy vote, and the cost and use of resources to recall the securities.
|
The delegation by the Board
of the authority to vote proxies relating to securities of the Fund is entirely voluntary and may be revoked by the Board, in whole
or in part, at any time without prior notice.
|
5.
|
Disclosure of Policy or Description/Proxy Voting Record
|
|
A.
|
The Fund will disclose a description of the Fund’s
proxy voting policy in the Fund’s Statement of Additional Information (“SAI”). The Fund also will disclose in
its SAI that information is available about how the Fund voted proxies during the most recent twelve-month period ended June 30
without charge, upon request, (i) either by calling a specified toll-free telephone number, or on the Fund’s website at
a specified address, or both, and (ii) on the Securities and Exchange Commission’s (“SEC”) website at http://www.sec.gov.
Upon any request for a proxy voting record by telephone, the Fund will send the policy or the information disclosed in the Fund’s
most recently filed report on Form N-PX (or a copy of the SAI containing the policy or description) by first-class mail or other
prompt delivery method within three business days of receipt of the request. If the Fund discloses that the Fund’s proxy
voting record is available on or through its website, the Fund will make available free of charge the information disclosed in
the Fund’s most recently filed report on Form N-PX on or through its website as soon as reasonably practicable after filing
the report with the SEC.
|
|
B.
|
The Fund will disclose in its annual and semi-annual
shareholder reports that this proxy voting policy or a description of it is available without charge, upon request, (i) by calling
a specified toll-free telephone number, (ii) on the Fund’s website, if applicable, and (iii) on the SEC’s website.
Upon any request for a proxy voting policy or description of it, the Fund will send the policy or the description (or a copy of
the SAI containing the policy or description) by first-class mail or other prompt delivery method within three business days of
receipt of the request.
|
|
C.
|
The Fund also will disclose in its annual and semi-annual
shareholder reports that information is available about how the Fund voted proxies during the most recent twelve-month period
ended June 30 without charge, upon request, (i) either by calling a specified toll free telephone number, (ii) on the Fund’s
website at a specified address, if applicable, and (iii) on the SEC’s website. Upon any request for a proxy voting record
by telephone, the Fund will send the policy or the information disclosed in the Fund’s most recently filed report on Form
N-PX (or a copy of the SAI containing the policy or description) by first-class mail or other prompt delivery method within three
business days of receipt of the request. If the Fund discloses that the Fund’s proxy voting record is available on or through
its website, the Fund will make available free of charge the information disclosed in the Fund’s most recently filed report
on Form N-PX on or through its website as soon as reasonably practicable after filing the report with the SEC.
|
|
D.
|
The Fund will file Form N-PX containing its proxy
voting record for the most recent twelve-month period ended June 30 with the SEC, and will provide a copy of the report (in paper
form, online, or by reference to the SEC’s website) to shareholders who request it.
|
|
E.
|
The Fund will disclose its proxy voting record for
the most recent twelve-month period ended June 30 (on Form N-PX or otherwise) to shareholders either in paper form upon request,
or on its website.
|
The Fund currently satisfies the disclosure obligation
set forth in Section 5 above by:
|
•
|
describing the proxy voting policy in the Fund’s
SAI and disclosing in the Fund’s SAI that the information is available about how the Fund voted proxies during the most
recent twelve-month period ended June 30 without charge, upon request by calling a specified toll-free telephone number and on
the Commission’s website;
|
|
•
|
disclosing in its annual and semi-annual shareholder
reports that this proxy voting policy is available without charge, upon request by calling a specified toll-free telephone number
and on the Commission’s website;
|
|
•
|
disclosing in its annual and semi-annual shareholder
reports that information is available about how the Fund voted proxies during the most recent twelve-month period ended June 30
without charge, upon request, by calling a specified toll-free telephone number and on the Commission’s website; and
|
|
•
|
providing any shareholder, upon request, a paper form
of the most recently filed report on Form N-PX by first-class mail or other prompt delivery method within three business days
of receipt of the request.
|
Proxy voting books and records
shall be maintained and preserved in an easily accessible place for a period of not less than five years from the end of the fiscal
year during which the last entry was made on the record, the first two years in office of the Adviser or Subadviser, as applicable.
The Adviser and Subadviser
shall maintain the following records relating to proxy voting:
|
•
|
a copy of these policies and procedures;
|
|
•
|
a copy of each proxy form (as voted);
|
|
•
|
a copy of each proxy solicitation (including proxy
statements) and related materials;
|
|
•
|
documentation relating to the identification and resolution
of conflicts of interest;
|
|
•
|
any documents created by the Adviser or Subadviser
that were material to a proxy voting decision, including a decision to abstain from voting, or that memorialized the basis for
that decision; and
|
|
•
|
a copy of each written request from an investor for
the Fund’s proxy voting policies and procedures and/or information on how the Adviser or Subadviser voted proxies, and a
copy of any written response by the Adviser or Subadviser to any such requests.
|
The Board shall review from time to time this policy
to determine its sufficiency and shall make and approve any changes that it deems necessary from time to time.
Adopted: August 22, 2013
Amended: May 14, 2015
Amended: June 21, 2018
Amended: August 27, 2019
Item 8. Portfolio Managers of Closed-End Management Investment
Companies.
|
(a)(1)
|
Identification of Portfolio Manager(s) or Management
Team Members and Description of Role of Portfolio Manager(s) or Management Team Members
|
James R. Fellows,
Chief Investment Officer and Managing Director, First Eagle Alternative Credit, LLC (“FEAC”), the Fund’s investment
adviser. James has worked for FEAC’s senior loan strategies business from June 2012 to present. Between April 2004 and June
2012, James served as Managing Director for McDonnell Investment Management, LLC, whose alternative credit strategies business
was the predecessor firm to FEAC’s senior loan strategies business.
Brian W. Good,
Managing Director, FEAC. Brian has worked for FEAC’s senior loan strategies business from June 2012 to present. Between April
2004 and June 2012, Brian served as Managing Director for McDonnell Investment Management, LLC, whose alternative credit strategies
business was the predecessor firm to FEAC’s senior loan strategies business.
Robert J. Hickey,
Managing Director, FEAC. Robert has worked for FEAC’s senior loan strategies business from June 2012 to present. Between
April 2004 and June 2012, Robert served as Managing Director for McDonnell Investment Management, LLC, whose alternative credit
strategies business was the predecessor firm to FEAC’s senior loan strategies business.
Brian J. Murphy,
Managing Director, FEAC. Brian has worked for FEAC’s senior loan strategies business, June 2012 to present. Between May 2004
and June 2012, Brian served as Managing Director for McDonnell Investment Management, LLC, whose alternative credit strategies
business was the predecessor firm to FEAC’s senior loan strategies business.
Steven F. Krull,
Managing Director, FEAC. Steven has worked for FEAC’s senior loan strategies business, June 2012 to present. Between May
2004 and June 2012, Steven served as Director for McDonnell Investment Management, LLC, whose alternative credit strategies business
was the predecessor firm to FEAC’s senior loan strategies business.
James C. Camp,
CFA, Managing Director, Portfolio Manager, Eagle Asset Management, Inc. (“EAM”), the Fund’s sub-adviser. Mr.
Camp has 30 years of fixed income investment experience and is responsible for the management of all fixed income portfolios. Before
joining EAM in 1997, James was a Vice President in the Fixed Income Research and Mortgage Specialist Groups at Raymond James &
Associates following three years at ING Investment Management. Mr. Camp graduated with a B.S. in Engineering Science from Vanderbilt
University in 1986 and earned his M.B.A. in Finance from Emory University in 1990. He is a CFA charterholder.
David Blount,
CFA, CPA, Portfolio Co-Manager, EAM. Mr. Blount has 35 years of investment experience and is responsible for portfolio management,
as well as research in the consumer discretionary and consumer staples sectors. Prior to joining Eagle in 1993, David served as
an Investment Analyst for Allstate. He earned a B.S. in Finance from the University of Florida in 1983. Mr. Blount is a CFA charterholder
and a Certified Public Accountant.
Joseph Jackson,
CFA, Portfolio Co-Manager & Senior Credit Analyst, EAM. Mr. Jackson has 20 years of investment experience and is responsible
for analyzing corporate issues for Eagle's Fixed Income group. Prior to joining Eagle in 2004, he was Senior Vice President &
Corporate Bond Portfolio Manager at BB&T Asset Management, where he managed over $1 billion in corporate bonds, as well as
BB&T's Intermediate Corporate Bond Fund. Mr. Jackson earned a B.A. in 1990 and an M.B.A. in Finance and Investments in 1998,
both from Wake Forest University. He is a CFA charterholder.
Ed Cowart, CFA,
Portfolio Co-Manager, EAM. Mr. Cowart has 47 years of investment experience and is responsible for portfolio management, as well
as research in the energy and financial (ex-REITs) sector. He has been with Eagle since 1999. Prior to joining Eagle, he was Managing
Director of the Value Equity team at Bank One Investment Advisors, where he managed the One Group Large Cap Value Fund. His extensive
investment experience also includes positions as Director of Research for a regional broker/dealer and for the University of Texas'
Endowment Fund. Mr. Cowart earned an A.B. from Dartmouth College. He is a CFA charterholder.
Harald Hvideberg,
CFA, Portfolio Co-Manager, EAM. Mr. Hvideberg has 22 years of investment experience and is
responsible for portfolio management, as well as research in the technology, telecommunications, and utilities sectors. He joined
Eagle in 2014. Prior to joining Eagle, he was a portfolio manager at Wood Asset Management. Mr. Hvideberg earned a B.A. in Economics
in 1992 and a B.S. in finance in 1993, both from the University of South Florida and an M.B.A. from the University of Florida in
1997. He is a CFA charterholder.
The Portfolio
Managers employed noted above manage EGIF via a committee. Therefore, the day-to-day management of EGIF is shared among the Portfolio
Managers.
All information
provided is as of December 31, 2019.
|
(a)(2)
|
Other Accounts Managed by Portfolio Manager(s) or Management
Team Member and Potential Conflicts of Interest
|
Name of Portfolio Manager or
Team Member
|
Type of Accounts
|
Total
No. of Accounts Managed
|
Total Assets
|
No. of Accounts where Advisory Fee is Based on Performance
|
Total Assets in Accounts where Advisory Fee is Based on Performance
|
James R. Fellows
|
Registered Investment Companies:
|
5
|
$ 849 million
|
1**
|
$0
|
|
Other Pooled Investment Vehicles:
|
44
|
$15.3 billion
|
6
|
$14.4 billion
|
|
Other Accounts:
|
4
|
$1.1 billion
|
0
|
$0
|
Brian W. Good
|
Registered Investment Companies:
|
4
|
$409 million
|
0
|
$0
|
|
Other Pooled Investment Vehicles:
|
37
|
$14.1 billion
|
30***
|
$13.2 billion
|
|
Other Accounts:
|
4
|
$1.1 billion
|
0
|
$0
|
Robert J. Hickey
|
Registered Investment Companies:
|
4
|
$409 million
|
0
|
$0
|
|
Other Pooled Investment Vehicles:
|
38
|
$14.2 billion
|
31***
|
$13.3 billion
|
|
Other Accounts:
|
5
|
$1.1 billion
|
1
|
$2.3 million
|
Brian J. Murphy
|
Registered Investment Companies:
|
4
|
$409 million
|
0
|
$0
|
|
Other Pooled Investment Vehicles:
|
37
|
$14.1 billion
|
30***
|
$13.2 billion
|
|
Other Accounts:
|
4
|
$1.1 billion
|
0
|
$0
|
Steven F. Krull
|
Registered Investment Companies:
|
4
|
$409 million
|
0
|
$0
|
|
Other Pooled Investment Vehicles:
|
37
|
$14.1 billion
|
30***
|
$13.2 billion
|
|
Other Accounts:
|
4
|
$1.1 billion
|
0
|
$0
|
James C. Camp
|
Registered Investment Companies:
|
0
|
0
|
0
|
0
|
|
Other Pooled Investment Vehicles:
|
0
|
0
|
0
|
0
|
|
Other Accounts:
|
9,141
|
$7.2 billion
|
0
|
0
|
David Blount
|
Registered Investment Companies:
|
1
|
$878 million
|
0
|
0
|
|
Other Pooled Investment Vehicles:
|
0
|
0
|
0
|
0
|
|
Other Accounts:
|
872
|
$446 million
|
0
|
0
|
Joseph Jackson
|
Registered Investment Companies:
|
0
|
0
|
0
|
0
|
|
Other Pooled Investment Vehicles:
|
0
|
0
|
0
|
0
|
|
Other Accounts:
|
9,141
|
$7.2 billion
|
0
|
0
|
Ed Cowart
|
Registered Investment Companies:
|
1
|
$878 million
|
0
|
0
|
|
Other Pooled Investment Vehicles:
|
0
|
0
|
0
|
0
|
|
Other Accounts:
|
872
|
$446 million
|
0
|
0
|
Harald Hvideberg
|
Registered Investment Companies:
|
1
|
$878 million
|
0
|
0
|
|
Other Pooled Investment Vehicles:
|
0
|
0
|
0
|
0
|
|
Other Accounts:
|
872
|
$446 million
|
0
|
0
|
* Information
as of December 31, 2019, except as noted, and is unaudited.
**Includes
one business development company (the “BDC”), as of September 30, 2019, for which the performance fee was waived in
2019. Therefore, no assets of the BDC are included in the “Total Assets in Accounts where Advisory Fee is Based on Performance”.
*** Includes
one pooled investment vehicle which is currently in wind down and three called CLOs, and no performance based fee is being received/billed
from the vehicles, so assets of the wind down portfolio and the called CLOs are not included in “Total Assets in Accounts
where Advisory Fee is Based on Performance”. Also, twenty-six other accounts noted in this column represent Collateralized
Loan Obligation Vehicles (CLOs) where the performance fees of a CLO are achieved based on a pre-defined percentage based internal
rate of return (IRR) hurdle for holders of the subordinated notes of the CLO.
Potential Conflicts of Interests
The Portfolio Managers may be
subject to certain conflicts of interest in their management of the Fund. These conflicts could arise primarily from the involvement
of FEAC and EAM (collectively, the “Advisers”) and their respective affiliated entities (“Affiliates”)
in other activities that may conflict with those of the Fund. The Advisers’ Affiliates engage in a broad spectrum of activities.
In the ordinary course of their business activities, the Advisers’ Affiliates may engage in activities where the interests
of the Affiliates or the interests of their clients may conflict with the interests of the Fund. Other present and future activities
of the Affiliates may give rise to additional conflicts of interest which may have a negative impact on the Fund. In addition,
the Portfolio Managers or other management team members of the Advisers serve or may serve as Portfolio Managers or management
team members of entities that operate in the same or a related line of business, or of accounts sponsored or managed by the Affiliates.
In serving in these multiple capacities, they may have obligations to other clients or investors in those entities, the fulfillment
of which may not be in the best interests of the Fund.
In addressing these conflicts
and regulatory, legal and contractual requirements across its various businesses, certain members of the Advisers and the Affiliates
have implemented certain policies and procedures (e.g., information walls). For example, the Advisers and their Affiliates may
come into possession of material non-public information with respect to companies in which the Advisers may be considering making
an investment or companies that are advisory clients of the Advisers and their Affiliates. As a consequence, that information,
which could be of benefit to the Fund, could also restrict the Fund’s activities and the investment opportunity may otherwise
be unavailable to the Fund. Additionally, the terms of confidentiality or other agreements with or related to companies in which
any account managed by the Advisers has or has considered making an investment or which is otherwise an advisory client of the
Advisers and their Affiliates may restrict or otherwise limit the ability of the Advisers to direct investments in such companies.
The Advisers and their Affiliates
may participate on creditors’ committees with respect to the bankruptcy, restructuring or workout of issuers. In such circumstances,
the Advisers may take positions on behalf of themselves and other accounts and clients that are adverse to the interest of other
clients. As a result of such participation, the Advisers may be restricted in trading in such issuers or securities of said issuers.
The Investment Company Act of
1940, as amended (“1940 Act”), also prohibits certain “joint” transactions with certain of the Advisers’
Affiliates, which could include making investments in the same portfolio company (whether at the same or different times). As a
result of these restrictions, the Advisers may be prohibited in some cases from buying or selling any security directly from or
to any portfolio company of a fund managed by an Affiliate. These limitations may limit the scope of investment opportunities that
would otherwise be available to the Fund.
All of the transactions described
above involve the potential for conflicts of interest between the Advisers (or their employees) and the Fund. The Investment Advisers
Act of 1940, as amended, and the 1940 Act impose certain requirements designed to mitigate the possibility of conflicts of interest
between an investment adviser and its clients. In some cases, transactions may be permitted subject to fulfillment of certain conditions.
Certain other transactions may be prohibited. The Advisers have instituted policies and procedures designed to prevent conflicts
of interest from arising and, when they do arise, to ensure that it effects transactions for clients in a manner that is consistent
with the Advisers’ fiduciary duties to the Fund and in accordance with applicable law. The Advisers seeks to ensure that
potential or actual conflicts of interest are appropriately resolved taking into consideration the overriding best interest of
the applicable Fund or client account.
|
(a)(3)
|
Compensation Structure of Portfolio Manager(s) or Management
Team Members
|
The Portfolio Managers of the
Fund’s adviser (the “FEAC Portfolio Managers”) are employed by First Eagle Alternative Credit SLS, LLC (“FEAC
SLS”), a subsidiary of FEAC, and provide services to FEAC through a staffing arrangement. FEAC SLS offers all investment
professionals the opportunity to receive a performance bonus, in addition to their annual salary, which is based in part on the
performance of firm overall, rather than specific accounts.
The FEAC Portfolio Managers are
evaluated based on a set of objective performance criteria where a numerical scoring framework is applied. Annual investment performance
is a significant component of that score, with the contribution amount varied pursuant to the FEAC Portfolio Manager’s experience
and seniority. In addition, management finds it valuable and fair to look at all decisions made, not simply the ones that resulted
in assets entering or leaving the portfolios. In addition to the FEAC Portfolio Manager’s salary and annual bonus, FEAC offers
employees significant benefits. Benefits include 401k company matching, health, dental, disability and life insurance coverage
as well as paid vacation time.
Generally, the FEAC Portfolio
Managers are offered compensation levels that are viewed as competitive within the investment industry and benchmarked to industry
data. Specifically, the professional staff is compensated with a base salary in addition to a yearly bonus that is based on company,
group and individual performance. The intent of this compensation plan is the long term alignment of interests between the investment
team and our clients over a multi-year period. Relative outperformance and client satisfaction over time will often lead to improved
fund flows and thus a more robust bonus pool.
With respect to the Fund’s
sub-adviser, professional compensation at EAM for Investment Personnel is structured so that key professionals benefit from staying
with EAM. Each portfolio manager receives a fixed base salary and a cash bonus payable every year. A portion of the bonus is deferred
pursuant to the practice of EAM. The bonus is determined at the discretion of senior management of EAM, and is based on a qualitative
analysis of several factors, including the profitability of EAM and the contribution of the individual employee. Many of the factors
considered by management in reaching its compensation determinations will be impacted by the long-term performance and the value
of assets held in the Fund as well as the portfolios managed for EAM’s other clients. However, there are no set formulas
and no benchmarks considered in these determinations, which are not quantitative in any way. When portfolio managers also perform
additional management functions within EAM, those contributions may also be considered in the determination of bonus compensations.
|
(a)(4)
|
Disclosure of Securities Ownership
|
"Beneficial ownership" should
be determined in accordance with rule 16a-1(a)(2) under the Exchange Act (17 CFR 240.16a-1(a)(2)).
Name of Portfolio
Manager or
Team Member
|
|
Dollar ($) Range of
Fund Shares
Beneficially Owned*
|
|
|
|
James R. Fellow
|
|
$0
|
Brian W. Good
|
|
$0
|
Robert J. Hickey
|
|
$0
|
Brian J. Murphy
|
|
$0
|
Steven F. Krull
|
|
$0
|
James C. Camp
|
|
$100,001 - $500,000
|
David Blount
|
|
$50,001 - $100,001
|
Joseph Jackson
|
|
$0
|
Ed Cowart
|
|
$0
|
Harald Hvideberg
|
|
$0
|
*Information as of December 31, 2019.
Item 9. Purchases of Equity
Securities by Closed-End Management Investment Company and Affiliated Purchasers.
REGISTRANT PURCHASES
OF EQUITY SECURITIES
Period
|
Total
Number of
Shares (or
Units) Purchased
|
Average
Price Paid
per Share
(or Unit)
|
Total Number of
Shares (or Units)
Purchased as Part of
Publicly Announced
Plans or Programs
|
Maximum Number (or
Approximate Dollar Value)
of Shares (or Units) that May
Yet Be Purchased Under the
Plans or Programs*
|
December 13 – 31, 2019
|
56,051
|
$16.97
|
56,051
|
662,036 shares
|
Total
|
56,051
|
$16.97
|
56,051
|
662,036 shares
|
* On November 21, 2019, the Fund announced
a share repurchase program authorizing the Fund to repurchase up to 10% of its then currently outstanding shares. The repurchase
program will expire on November 30, 2020.
Item 10. Submission of Matters to a Vote of Security Holders.
There have been no material changes to
the procedures by which the shareholders may recommend nominees to the registrant’s board of trustees, where those changes
were implemented after the registrant last provided disclosure in response to the requirements of Item 407(c)(2)(iv) of Regulation
S-K (17 CFR 229.407) (as required by Item 22(b)(15) of Schedule 14A (17 CFR 240.14a-101)), or this Item.