Law Offices

Stradley Ronon Stevens & Young, LLP

2005 Market Street, Suite 2600

Philadelphia, PA 19103-7081

(215) 564-8600

December 22, 2022

Filing Desk

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

Ladies and Gentlemen:

Pursuant to the requirements of Rule 14a-6(a) under the Securities Exchange Act of 1934, as amended, and submitted electronically via the EDGAR system, please find enclosed a Schedule 14(a) Information cover page, preliminary notice of a special meeting of shareholders, preliminary proxy statement and form of proxy cards to be furnished to shareholders of the Trust, in connection with a meeting of shareholders that is scheduled to be held on March 8, 2023.

Please direct any questions or comments relating to this filing to me at (215) 564-8149, or, in my absence, to E. Taylor Brody, Esq., at (215) 564-8071.