callable/putable bond

[KathleenJ-AMIC]

Good afternoon,

We are invested in Prime Notes LLC CUSIP 74166WAA2 and have it rated from AVS+ as 1.B PL on Schedule D Part 1. This security is callable/putable on every monthly coupon payment date but the maturity date is 2/16/2023. Vision has it categorized as a medium term note (categorized maturing between 5 and 10 years). Is there any possibility that this could be reported as a short-term bond or would you agree it should remain as a long-term bond?

Thank you,
Kathleen

[Lisa]

Kathleen,

Per the annual statement instructions for Schedule DA SHORT TERM INVESTMENTS OWNED DECEMBER 31 OF CURRENT YEAR, ?Include all investments whose maturities (or repurchase dates under repurchase agreement) at the time of acquisition were one year or less except those defined as cash or cash equivalents in accordance with SSAP No. 2R?Cash, Cash Equivalents, Drafts and Short Term Investments.

Also, SSAP 26R Bonds, paragraphs 9 and 10 discusses callable bonds and reporting.

Based on the information provided in the question, I don?t believe it would be appropriate to reclassify your bond to short-term investments.

The AVS+ website has contact information if you want to better understand and discuss the classification of this particular bond.

Regards,
Lisa Mullen
Regulatory Education Director