Liquidity and capital resources

3. Please revise to clearly disclose the risks that being based in China poses to investors. In particular, describe the significant regulatory, liquidity, and enforcement risks with cross-references to the more detailed discussion of these risks in the prospectus. For example, specifically discuss risks arising from the legal system in China, including risks and uncertainties regarding the enforcement of laws and that rules and regulations in China can change quickly with little advance notice; and the risk that the Chinese government may intervene or influence your operations at any time, or may exert more control over offerings conducted overseas and/or foreign investment in China-based issuers, which could result in a material change in your operations and/or the value of the securities you are registering for sale. Acknowledge any risks that any actions by the Chinese government to…

10. Please revise to clearly disclose the minimum period of time that you will be able to conduct planned operations using only currently available capital resources. We refer you to FRC 501.03(a) and Section IV of SEC Interpretive Release 33-8350.

1. We note your response to comment 1 indicates that your "use of the 'primary working capital' metric is more appropriately categorized as a key performance indicator (KPI)." It is our understanding that primary working capital is a non-GAAP measure and, therefore, it needs to comply with applicable rules that generally prohibit excluding charges or liabilities that required or will require cash settlement from non-GAAP liquidity measures. Accordingly, please revise future filings to ensure the measure complies with Item 10(e)(1)(ii)(A) of Regulation S-K.

Comment 11: In the section entitled “Additional Investment Strategies,” please consider deleting “or for liquidity purposes” from “Temporary Defensive Positions” to align with the requirements as set forth in Instruction 6 to Item 9 of Form N-1A. Additionally, please delete “also” in the following sentence: “Under such conditions, the Fund may also invest without limit in investment grade securities and may invest in U.S. government securities or other high quality money market instruments.”

2. Disclose that cash proceeds associated with the exercises of the warrants are dependent on the stock price in the prospectus summary, risk factors, MD&A and use of proceeds section. As applicable, describe the impact on your liquidity and update the discussion on the ability of your company to fund your operations on a prospective basis with your current cash on hand.

5. In light of the significant number of redemptions and the unlikelihood that the company will receive significant proceeds from exercises of the warrants because of the disparity between the exercise price of the warrants and the current trading price of the common stock, expand your discussion of capital resources to address any changes in the company’s liquidity position since the business combination. If the company is likely to have to seek additional capital, discuss the effect of this offering on the company’s ability to raise additional capital.

1. The discussion of the risks related to your Up-C structure, the Tax Receivable Agreement and the resulting redirection of cash flows to the pre-business combination owners should be enhanced and given more prominence in your prospectus. Please revise your prospectus cover page to disclose that the TRA confers significant economic benefits to the pre-business combination owners, redirects cash flows to the TRA participants at the expense of the rest of your shareholders, and materially affects your liquidity. Please ensure that your revised disclosure states clearly that you expect the payments to be substantial and that the arrangement will reduce the cash provided by the tax savings that would otherwise have been available to you for other uses. Because the arrangement could be considered a windfall for the pre-business combination owners, your disclosure should quantify the range…

Comment 19: Please tailor Liquidity Risk disclosure to the Fund’s intended investments in shares of ETFs.

Comment 13: Please explain supplementally how liquidity risk is applicable to the Underlying ETFs given that the minimum market cap and trading cap requirements.

Comment : The Staff notes that, according to the fee and expense table included in the Summary of Fund Expenses section of the Fund’s prospectus, the expenses attributable to interest payments on borrowed funds pursuant to the Fund’s liquidity agreement with State Street Bank and Trust Company (the “Liquidity Agreement”) were 0.41%, which is in line with the average annual interest rate on the Fund’s borrowings for the year ended October 31, 2022, as disclosed in the Fund’s annual shareholder report (the “Annual Report”). The Staff further notes that, according to note 7 of the Fund’s notes to financial statements in the Annual Report, that the Fund had average borrowings of $103 million at an annual interest rate of 3.80% for the year ended October 31, 2022 and that interest on borrowings outstanding under the Liquidity Agreement is charged at a rate of 1-month LIBOR plus 0.50%. Please…

3. Under “Security Selection” it states, “[w]hen selecting the ETFs the sponsor looks at numerous factors. These factors include, but are not limited to: maturity and liquidity.” Please disclose any additional factors that the sponsor considers in selecting ETFs for inclusion in the trust’s portfolio.

Comment : All Funds: The annual report for the Reynders, McVeigh Core Equity Fund includes the liquidity risk management program review (as it pertains to Item 27d-6 in Form N1-A), but the other funds’ reports that were reviewed did not include the disclosure. Provide explanation.

1. We note your response to prior comment 29 regarding your Hong Kong operations, sales and regulatory risks. You differentiate the regulatory environment in Hong Kong for foreign-owned entities operating in the People's Republic of China. Please expand your discussion to describe the more restrictive regulatory, liquidity, and enforcement risks for foreign-owned entities operating in China, and clarify that such rules and regulations can change quickly with little advance notice. Further, your risk factor should highlight that the Chinese government may intervene or influence your Hong Kong operations in similar ways to how it regulates its mainland China activities, and such actions may lead to negative consequences to your Hong Kong operations.

4. Please revise your disclosure to clarify whether there could be discrepancies between the trading prices of common shares on the NYSE American and the tokenized shares on Upstream, whether resulting from different liquidity in the markets or otherwise, and disclose the risks this presents to investors.

Comment : With respect to the “statement regarding liquidity risk management program” for Funds 1 and 11 in the corresponding shareholder reports filed on Form N-CSR, please consider referencing the review conducted by the Funds’ board of trustees.

Comment : With respect to Funds 1 and 11, please explain why Item E.5 ( In-Kind ETF ) was not answered “Yes”; the Staff notes that the “statement regarding liquidity risk management program” (“LRM statement”) in the respective shareholder reports indicates that each Fund is considered an In-Kind ETF as defined in Rule 22e-4 under the 1940 Act (“In-Kind ETF”).

Comment: In the risk factor “Liquidity Risk,” please explain the context of this risk given that the strategy invests in publicly-traded equity securities.

Comment : The Staff notes that the Goldman Sachs Financial Square Prime Obligations and Goldman Sachs Financial Square Money Market Funds’ prospectus states that the Funds have the ability to charge liquidity fees or implement redemption gates in accordance with Rule 2a-7. However, these features have not been disclosed in the Notes to the Financial Statements. Supplementally, explain why these features have been omitted. In future reports, please include disclosure in the Financial Statements regarding liquidity fees and redemption gates and related accounting policies as applicable.

Comment : With respect to the third and fourth paragraphs in the section of the Fund’s Prospectus titled “ PRINCIPAL INVESTMENT STRATEGIES ”, please specify whether all issuers that meet the market capitalization requirement and liquidity requirement are included in the Underlying Index. Please specify whether an issuer could meet these criteria but still be excluded from the Underlying Index. If so, please discuss on what basis an issuer may be excluded from the Underlying Index.

1. You disclosed that you continue to be affected by ongoing supply chain disruptions. Please revise MD&A in future filings to more fully address whether supply chain disruptions materially affect your outlook or business goals. Quantify and disclose, to the extent possible, how your revenues, profits, and/or liquidity have been impacted, and discuss known trends or uncertainties resulting from mitigation efforts undertaken, including whether any mitigation efforts introduce new material risks, including those related to product quality, reliability, or regulatory approval. CAE

8. To the extent material, please explain whether, to your knowledge, crypto assets you have issued serve as collateral for any other person’s or entity’s loan, margin, rehypothecation or similar activity. If so, discuss whether the current crypto asset market disruption has impacted the value of the underlying collateral and explain any material financing and liquidity risk this raises for your business.

Comment : In connection with Comment and Response 8 above, please disclose that it may take longer than 7 days for transactions in leveraged loans to settle, which means it could take the Fund significant time to get its money after selling its investment. Please also address how the Fund intends to meet short-term liquidity needs which may arise as a result of this lengthy settlement period. If the Fund will hold a significant amount of covenant-lite loans, please revise principal risks disclosure to include the heightened risks associated with covenant-lite loans. Registrant’s

4. With a view toward disclosure, please clarify whether there could be discrepancies between the trading prices of common shares on Nasdaq and the tokenized shares on Upstream, whether resulting from different liquidity in the markets or otherwise.

1. Please revise MD&A in future annual and quarterly filings to more fully address the following: • You disclose that results for fiscal year 2022 were negatively impacted by certain challenges, including supply chain disruptions. Please discuss whether and how supply chain disruptions materially affect your outlook or business goals. Quantify and disclose, to the extent possible, how sales, profits, and/or liquidity have been impacted and discuss known trends or uncertainties resulting from mitigation efforts undertaken, including whether any mitigation efforts introduce new material risks, including those related to product quality, reliability, or approval. • You disclose here, and in quarterly filings, that you are experiencing ongoing inflationary cost increases. Please quantify and disclose the impact of the inflationary pressures you experience, including the combined impact of…

3. We note your calculation of the non-GAAP liquidity measure you identify as “free cash flow” appears to differ from the standard calculation of this measure (i.e., cash flows from operations less capital expenditures). In order to avoid potential confusion, please revise the title of your non-GAAP liquidity measure in future filings to “adjusted free cash flow” or something similar. Refer to Question 102.07 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. Carpenter Technology

2. To the extent you intend to proceed with your offering if your NASDAQ listing is denied, revise your cover page to indicate that the offering is not contingent on NASDAQ approval of your listing application and that if the shares are not approved for listing, you may experience difficulty selling your shares. Include risk factor disclosures to address the impact on liquidity and the value of shares. Company

8. Disclose the risks that your corporate structure and being based in or having the majority of the company’s operations in China poses to investors. In particular, describe the significant regulatory, liquidity, and enforcement risks. For example, specifically discuss risks arising from the legal system in China, including risks and uncertainties regarding the enforcement of laws and that rules and regulations in China can change quickly with little advance notice; and the risk that the Chinese government may intervene or influence your operations at any time, or may exert more control over offerings conducted overseas and/or foreign investment in China-based issuers, which could result in a material change in your operations and/or the value of your securities. Acknowledge any risks that any actions by the Chinese government to exert more oversight and control over offerings that are…

22. On p. 13, in the third paragraph under “Liquidity Risk,” in the second to last sentence, please clarify here and throughout as applicable that any partial withdrawal is subject to a proportionate reduction. Disclosure here seems to suggest that proportional adjustment may only apply if a withdrawal is taken during a Crediting Period or at the end of a Crediting Period during the first six Contract Years.

4. With a view toward disclosure, please clarify whether there could be discrepancies between the trading prices of common shares on Nasdaq and the tokenized shares on Upstream, whether resulting from different liquidity in the markets or otherwise.

2. Disclose the exercise prices of the warrants compared to the market price of the underlying ordinary shares. If the warrants are out of the money, please disclose the likelihood that warrant holders will not exercise their warrants. Similarly, if the market price of the ordinary shares are close to the exercise price, clarify that the amount of ordinary shares that are offered as part of this offering may provide downward pressure on the ordinary share market price, which may result in the market price being out of the money. Provide similar disclosure in the prospectus summary, risk factors, MD&A and use of proceeds section and disclose that cash proceeds associated with the exercises of the warrants are dependent on the stock price. As applicable, describe the impact on your liquidity and update the discussion on the ability of your company to fund your operations on a prospective…

4. We note that your projected revenues for 2021 and 2022 were $45,163,329 and $64,950,000, respectively, as set forth in the unaudited prospective financial information management prepared and provided to the Board, the company’s financial advisors and Global SPAC Partners in connection with the evaluation of the Business Combination. We also note that your actual revenues for the six months ended June 30, 2022 was approximately $13.8 million. It appears that you will miss your 2022 revenue projection by a significant amount. Although you only missed your revenue projection for fiscal year 2021 by several million dollars, your failed to achieve your other projected financial information such as gross profit, EBITDA and operating cash flow by material amounts. Please update your disclosure in Liquidity and Capital Resources, and elsewhere, to provide updated information about the…

5. In light of the significant number of redemptions and the unlikelihood that the company will receive significant proceeds from exercises of the warrants because of the disparity between the exercise price of the warrants and the current trading price of the ordinary shares, expand your discussion of capital resources to address any changes in the company’s liquidity position since the business combination. If the company is likely to have to seek additional capital, discuss the effect of this offering on the company’s ability to raise additional capital.

12. Revise to expand your liquidity disclosures to include a discussion that analyzes material cash requirements from known contractual and other obligations, including specification of the type of obligation and the relevant time period for the related cash requirements, as required by Item 303(b)(1) of Regulation S-K. In that regard, we note you disclosed certain lease obligations as well as obligations under license agreements.

18. In future filings, please disclose whether you have experienced excessive redemptions or withdrawals, or have suspended redemptions or withdrawals, of crypto assets and explain the potential effects on your financial condition and liquidity.

20. In future filings, to the extent material, explain whether, to your knowledge, crypto assets you have issued serve as collateral for any other person’s or entity’s loan, margin, rehypothecation or similar activity. If so, discuss whether the current crypto asset market disruption has impacted the value of the underlying collateral and explain any material financing and liquidity risk this raises for your business.

27. In future filings, please describe any material financing, liquidity, or other risks you face related to the impact that the current crypto asset market disruption has had, directly or indirectly, on the value of the crypto assets you use as collateral or the value of your crypto assets used by others as collateral.

4. With respect to your planned NFT platform, please identify the blockchain that you intend to utilize and include a description of the processes and fees related to the use of such blockchain. To the extent that you intend to develop your own blockchain, please provide a discussion regarding the functional differences between the blockchain you are developing and other popular blockchains used for minting NFTs (Ethereum, Solana, etc.). Be sure to include a discussion of the impact of transaction fees, lack of liquidity, and volatility as it relates to your NFT platform.

5. Please provide a more detailed discussion of your planned NFT platform with regards to its functionality and the range of crypto assets you intend to utilize. To the extent you will accept crypto assets as payments, or otherwise acquire crypto assets, provide a discussion regarding whether you have a specific policy in place regarding when and how you will convert those crypto assets into fiat currency. Tell us whether you will maintain any royalty interest or intellectual property ownership of the NFTs sold on your platform. For example, explain whether the platform will permit creators or the company to receive a portion of all subsequent sales of each NFT, or only on the initial sale. Discuss the intellectual property underlying the NFTs and explain to us how disputes over such rights will be resolved and your role in such resolution, including your role in the enforcement of such…

1. The Staff notes that the disclosure states, “The ETFs were selected by our research department based on a number of factors including, but not limited to, the size and liquidity of the ETFs (requiring a minimum market capitalization of $50,000,000), the current dividend yield of the ETFs (prioritizing ETFs with the highest dividend yields) and the quality and character of the securities held by the ETFs (focusing on credit quality, maturity and duration, which are balanced to varying degrees based on current economic conditions).” Please add “and subject to the Trust’s policy of having a weighted average modified duration of four years or less.”

2. To the extent you intend to proceed with your offering if your NASDAQ listing is denied, revise your cover page to indicate that the offering is not contingent on NASDAQ approval of your listing application and that if the shares are not approved for listing, you may experience difficulty selling your shares. Include risk factor disclosures to address the impact on liquidity and the value of shares.

Comment 8: Please supplementally describe if the board reviewed, at least annually, a written report on the adequacy of the liquidity risk management program and the effectiveness of its implementation and is in compliance with Rule 22e-4(b)(2)(iii) of the 1940 Act. In future filings, in the Fund’s disclosure Ms. Christina DiAngelo Fettig Page 4 regarding the Liquidity Risk Management Program, please consider including that the Board also reviewed the Liquidity Risk Management Program.

7. The Principal Investment Strategies section discloses that the Fund may invest in junk bonds and unrated securities, as well as illiquid and thinly traded securities. Given the liquidity profile of such securities, please supplementally explain how the Fund has determined that its investment strategy is appropriate for the open-end fund structure. Your response should include general market data on the liquidity of such securities and information concerning the 2 relevant factors discussed in the release adopting Rule 22e-4 under the 1940 Act. See Investment Company Act Release No. 32315 (Oct. 13, 2016).

2. We note that the split-off proposal contemplates the redemption by Liberty Media of each outstanding share of BATRA, BATRB and BATRK “in exchange for one share of the corresponding series of common stock of” SplitCo. Here and in your sections entitled “Summary” and “Risk Factors,” please prominently describe the number of votes per share to which each series is entitled, as well as the circumstances or events in which the conversion of the various series of shares are mandatory or optional, including any exceptions. Additionally, in your risk factor discussion, please ● Disclose the risks that your multi-class capital structure may render your shares ineligible for inclusion in certain stock market indices, and thus adversely affect share price and liquidity. ● Disclose that future issuances of New BATRB shares may be dilutive to the holders of New BATRA, particularly with respect to…

20. In connection with the split-off, you plan to enter agreements with Liberty Media to include a services agreement, aircraft time sharing agreements, a facilities sharing agreement, a tax sharing agreement and a registration rights agreement. Please disclose any material favorable or unfavorable impact these agreements may have on your results of operations and/or liquidity. Refer to Item 303(b) of Regulation S-K.

24. Refer to the How Ripple’s On-Demand Liquidity works with Tranglo graphic on page 181. Please revise to more clearly describe to what each step relates and who fulfills it. For example, in step 1, describe what the term prefunding request means, why there is an FX quote if the example indicates the request is for USD 100,000, and who fulfills the prefunding request and how.

25. We note your revised disclosure in response to comment 43. Please revise this risk factor as well as your discussion of your relationship with Ripple on pages 180 and 207 to disclose that the on-demand liquidity remittance services are not available in the United States or to U.S. persons. Also include a detailed discussion of the know-your-customer process that you use to prevent access in the U.S. or by U.S. persons. To the extent material, describe any gaps your board or management have identified with respect to risk management processes and policies in light of current crypto asset market conditions and the volatility in the price of XRP, as well as any changes made to address those gaps.

26. Please revise to expand your related risk factor on page 54, or add a new risk factor as appropriate, to explain the specific regulatory issues under U.S. law that could arise if your on-demand liquidity services were accessed by U.S. persons or persons in the United States, and the material risk that could result. Tell us why you believe that the risk of access by such persons is “limited.” Ensure that your risk factor describes all material risks you face from unauthorized or impermissible customer access to your products and services outside of the jurisdictions where you or your partner have obtained the required governmental licenses and authorizations, and also include any potential risks associated with your know-your-customer and anti-money laundering processes and procedures that could result in the inability to prevent unauthorized or impermissible customer access. Also…

27. We note your revisions in response to comment 50. So that investors are better able to understand the extent to which the use of on-demand liquidity has impacted your financial performance, please revise your risk factor on page 54 to quantify the increase in ODL transactions and the corresponding decrease in average transaction fee take rate, average Forex gain take rate, and the corresponding decrease in total revenue.

33. We note your response to comment 58. Please provide us with a comprehensive analysis of the five steps in ASC 606-10-05-4 as it applies to how Ripple’s On-Demand Liquidity works with Tranglo in the diagram on page 181. We also note from your response and steps 3 and 4 in the diagram on page 181 that Tranglo takes custody of XRP only momentarily and it is immediately and automatically liquidated into fiat currencies through a programmatic liquidation arrangement with the cryptocurrency exchange. Please provide us with your accounting for the receipt and subsequent liquidation of XRP referencing the authoritative guidance that supports your accounting treatment.

10. As applicable, in your risk factors, disclose the risks of having the majority of the company’s operations in or revenues from China or Hong Kong poses to investors. In particular, describe the significant regulatory, liquidity, and enforcement risks with cross- references to the more detailed discussion of these risks in the prospectus. For example, specifically discuss risks arising from the legal system in China, including risks and uncertainties regarding the enforcement of laws and that rules and regulations in China can change quickly with little advance notice; and the risk that the Chinese government may intervene or influence your operations at any time which could result in a material change in your operations and/or the value of the securities you are registering for sale.

1. Please address the following comments related to your presentation of net working capital (“NWC”) and NWC as a percentage of annualized net sales: • You describe NWC and the annualized percentage as “key metrics that measure our liquidity.” Tell us why you refer to these items as metrics and not non-GAAP measures. • We note that NWC is calculated as “current quarter accounts receivable, net of allowance for doubtful accounts, plus inventories and contract assets, less accounts payable” and that it excludes certain current liabilities. Tell us how your presentation complies with Item 10(e)(1)(ii)(A) of Regulation S-K, which generally prohibits excluding charges or liabilities that required or will require cash settlement from non-GAAP liquidity measures. Also see the third bullet of Question 102.10(a) of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.…

2. In light of the significant number of redemptions and the unlikelihood that the company will receive significant proceeds from exercises of the warrants because of the disparity between the exercise price of the warrants and the current trading price of your ordinary shares, expand your discussion of capital resources to address any changes in the company’s liquidity position since the business combination. If the company is likely to have to seek additional capital, discuss the effect of this offering on the company’s ability to raise additional capital.

Comment : The Market Risk disclosure provides that “ … [t]he U.S. Federal Reserve [(“Fed”)] has invested or otherwise made available substantial amounts of money to keep credit flowing through short-term money markets and has signaled that it will continue to adjust its operations as appropriate to support short-term money markets. Amid these efforts, concerns about the markets’ dependence on the Fed’s provision of liquidity have grown.” If there is anything to update with respect to current action taken by the Fed, please consider revising the disclosure.

Comment : The Staff notes that “Real Estate Investing Risk” is included as a principal risk. If there are any principal risks associated with investments in sub-prime mortgages, please disclose in the principal risk section as well as in the principal strategy section, and disclose that the liquidity of those types of securities could change dramatically over time.

Comment : A review of the Funds’ applicable annual reports on Form N-CSR showed that they had not included the required disclosure concerning the operation of their liquidity risk management program. This comment applies to all of the Funds listed on Appendix A except for the following: Delaware Ivy Accumulative Fund, Delaware Ivy Wilshire Global Allocation Fund, Macquarie Emerging Markets Portfolio, Macquarie Emerging Markets Portfolio II Fund, Macquarie Labor Select International Equity Portfolio Fund, Delaware Global Listed Real Assets Fund, Macquarie High Yield Bond Portfolio Fund, Macquarie Core Plus Bond Portfolio Fund, and Macquarie Large Cap Value Portfolio Fund. Please explain why the disclosure was not included.

Comment : Explain supplementally whether the Registrants’ Board of Trustees/Directors has received an annual written report from the Registrants’ Liquidity Risk Management Program administrator that addresses the operation of the program and assesses its adequacy and effectiveness of implementation, and any material changes to the program as required by Rule 22e-4(b)(2)(iii) under the 1940 Act. This applies to all of the funds except the following: Delaware Ivy Accumulative Fund, Delaware Ivy Wilshire Global Allocation Fund, Macquarie Emerging Markets Portfolio, Macquarie Emerging Markets Portfolio II Fund, Macquarie Labor Select International Equity Portfolio Fund, Delaware Global Listed Real Assets Fund, Macquarie High Yield Bond Portfolio Fund, Macquarie Core Plus Bond Portfolio Fund, and Macquarie Large Cap Value Portfolio Fund.

1. We note your presentation of "primary working capital" that is calculated as "accounts receivable, plus inventories, minus trade accounts payable” and that excludes certain current liabilities. Please tell us how your presentation complies with Item 10(e)(1)(ii)(A) of Regulation S-K, which generally prohibits excluding charges or liabilities that required or will require cash settlement from non-GAAP liquidity measures. Also see the third bullet of Question 102.10(a) of the Compliance and Disclosure Interpretation on Non-GAAP Financial Measures.

2. To the extent you intend to proceed with your offering if your NASDAQ listing is denied, revise your cover page to indicate that the offering is not contingent on NASDAQ approval of your listing application and that if the shares are not approved for listing, you may experience difficulty selling your shares. Include risk factor disclosures to address the impact on liquidity and the value of shares.

Comment : Within the Explanatory Note on page one, under the bolded language detailing why the investment might be considered speculative, please also provide in bullet points as applicable, that: a. Company Shares will not be registered under the Securities Act of 1933 and will be subject to substantial restrictions on transfer. Investment in the Company is suitable only for sophisticated investors and requires the financial ability and willingness to accept the high risks and lack of liquidity inherent in an investment in the Company; February 6, 2023 Page 2 b. The Company intends to invest primarily in privately-held funds for which very little public information exists. Such investments are also generally more vulnerable to economic downturns and may experience substantial variations in operating results; and c. The privately-held funds and below-investment-grade securities in which…

Comment : On Page 62, within the section discussing the risks associated with OID securities, please include the following risks: a. Use of PIK and OID securities may provide certain benefits to the fund’s adviser including increasing management fees and incentive compensation; b. The Fund may be required under the tax laws to make distributions of OID income to shareholders without receiving any cash. Such required cash distributions may have to be paid from offering proceeds or the sale of fund assets; and c. The required recognition of OID, including PIK, interest for U.S. federal income tax purposes may have a negative impact on liquidity, because it represents a non-cash component of the Fund’s taxable income that must, nevertheless, be distributed in cash to investors to avoid it being subject to corporate level taxation.