The Securities and Exchange Commission has not necessarily reviewed the information in this filing and has not determined if it is accurate and complete.
The reader should not assume that the information is accurate and complete. |
Form N-CEN/A Filer Information |
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-CEN ANNUAL REPORT FOR REGISTERED INVESTMENT COMPANIES | OMB APPROVAL |
| OMB Number: 3235-0729 Estimated average burden hours per response: 19.04 |
a. Report for period ending: | 2018-10-31 |
b. Does this report cover a period of less than 12 months? | ☐ Yes ☒ No |
a. Full name of Registrant | ABERDEEN GLOBAL DYNAMIC DIVIDEND FUND |
b. Investment Company Act file number ( e.g., 811-) | 811-21901 |
c. CIK | 0001362481 |
d. LEI | 2549008871AD4OJQWG76 |
a. Street 1 | 1735 MARKET STREET |
Street 2 | 32ND FLOOR |
b. City | PHILADELPHIA |
c. State, if applicable |
PENNSYLVANIA
|
d. Foreign country, if applicable |
UNITED STATES OF AMERICA
|
e. Zip code and zip code extension, or foreign postal code | 19103 |
f. Telephone number (including country code if foreign) | 215-405-5700 |
g. Public Website, if any | N/A |
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 |
Name of person (e.g., a custodian of records) | Telephone | Address | Briefly describe books and records kept at this location |
---|---|---|---|---|
#1 | State Street Bank and Trust Company | 617-786-3000 | 1 Lincoln Street Boston, MASSACHUSETTS 02111 UNITED STATES OF AMERICA | Custody and Accounting Records. |
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? | ☐ Yes ☒ No |
b. Is this the last filing on this form by the Registrant? | ☐ Yes ☒ No |
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? | ☒ Yes ☐ No |
i. Full name of family of investment companies | ABERDEENCF |
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). |
a. Indicate the classification of the Registrant by checking the applicable item | ☐
a. Open-end management investment company registered under the Act on Form N-1A
☒ b. Closed-end management investment company registered under the Act on Form N-2 ☐ c. Separate account offering variable annuity contracts which is registered under the Act as a management investment company on Form N-3 ☐ d. Separate account offering variable annuity contracts which is registered under the Act as a unit investment trust on Form N-4 ☐ e. Small business investment company registered under the Act on Form N-5 ☐ f. Separate account offering variable insurance contracts which is registered under the Act as a unit investment trust on Form N-6 ☐ g. Unit investment trust registered under the Act on Form N-8B-2 |
a. Is the Registrant the issuer of a class of securities registered under the Securities Act of 1933 ("Securities Act")? | ☒ Yes ☐ No |
a. Provide the information requested below about each person serving as director of the Registrant (management investment companies only): |
Director Record | Full Name | CRD number, if any | 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))? | Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-): |
---|---|---|---|---|
#1 | John Sievwright | 000000000 | No | 811-22485 811-21980 811-22986 811-22016 |
#2 | Martin Gilbert | 000000000 | Yes | 811-08266 811-06342 811-22016 811-21980 811-22132 811-04611 |
#3 | Nancy Yao Maasbach | 000000000 | No | 811-05770 811-22016 811-08266 811-21980 |
#4 | Gerald Malone | 000000000 | No | 811-22016 811-21980 811-22485 811-04611 811-04438 811-22132 811-06342 |
a. Provide the information requested below about each person serving as chief compliance officer (CCO) of the Registrant for purposes of rule 38a-1 (17 CFR 270.38a- 1): |
Chief compliance officer Record | Full Name | CRD Number, if any | Telephone | Address | Has the CCO changed since the last filing? | 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: |
---|---|---|---|---|---|---|
#1 | Joseph Andolina | 006931174 | XXXXXX | 1735 Market Street 32nd Floor Philadelphia, PENNSYLVANIA 19103 UNITED STATES OF AMERICA | Yes |
|
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. |
a. Were any matters submitted by the Registrant for its security holders' vote during the reporting period? | ☒ Yes ☐ No |
i. If yes, and to the extent the response relates only to certain series of the Registrant, indicate the series involved: |
Security Matter Series info Record | Series name | Series identification number |
---|---|---|
#1 | N/A | N/A |
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? | ☐ Yes ☒ No |
b. Has any proceeding previously reported been terminated? | ☐ Yes ☒ No |
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? | ☐ Yes ☒ No |
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? | ☒ Yes ☐ No |
i. If yes, were any claims filed under the policy during the reporting period with respect to the Registrant? | ☐ Yes ☒ No |
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. |
a. 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? | ☐ Yes ☒ No |
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? | ☐ Yes ☒ No |
a. Provide the information requested below about each principal underwriter: |
Principal underwriter Record | Full Name | SEC file number (e.g., 8-) | CRD number | LEI, if any | State, if applicable | Foreign country, if applicable | Is the principal underwriter an affiliated person of the Registrant, or its investment adviser(s) or depositor? |
---|---|---|---|---|---|---|---|
— | — | — | — | — | — | — | — |
b. Have any principal underwriters been hired or terminated during the reporting period? | ☐ Yes ☒ No |
a. Provide the following information about each independent public accountant: |
Public accountant Record | Full Name | PCAOB Number | LEI, if any | State, if applicable | Foreign country, if applicable |
---|---|---|---|---|---|
#1 | KPMG LLP | 185 | 5493003PVCIGA21K0K42 | NEW JERSEY | UNITED STATES OF AMERICA |
b. Has the independent public accountant changed since the last filing? | ☒ Yes ☐ No |
Instruction. Small business investment companies are not required to respond to this item. |
a. For the reporting period, did an independent public accountant's report on internal control note any material weaknesses? | ☐ Yes ☒ No |
a. 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? | ☐ Yes ☒ No |
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. |
a. 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? | ☐ Yes ☒ No |
a. 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? | ☐ Yes ☒ No |
a. 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)? | ☒ Yes ☐ No |
i. If yes, and to the extent the response relates only to certain series of the Registrant, indicate the series involved: |
Payment dividend series info Record | Series name | Series identification number |
---|---|---|
#1 | N/A | N/A |
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 |
a. Full Name of the Fund | ABERDEEN GLOBAL DYNAMIC DIVIDEND FUND |
b. Series identication number, if any | |
c. LEI | 2549008871AD4OJQWG76 |
d. Is this the first filing on this form by the Fund? | ☒ Yes ☐ No |
a. How many Classes of shares of the Fund (if any) are authorized? | 0 |
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 | Full name of Class | Class identification number, if any | Ticker symbol, if any | — | — | — | — |
---|
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" 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 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. |
a. Indicate if the Fund is any one of the types listed. 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. Exchange-Traded Fund ☐ ii. Exchange-Traded Managed Fund ☐ b. Index Fund ☐ c. 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. Interval Fund ☐ e. Fund of Funds ☐ f. Master-Feeder Fund ☐ g. Money Market Fund ☐ h. Target Date Fund ☐ i. Underlying fund to a variable annuity or variable life insurance contract ☒ N/A |
a. 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))? | ☐ Yes ☒ No |
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? | ☐ Yes ☒ No |
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? | ☐ Yes ☒ No |
b. Did the Fund lend any of its securities during the reporting period? | ☐ Yes ☒ No |
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund: |
Securities Lending Record | Full name of securities lending agent | LEI, if any | Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? | Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? | — | — | — | — | — |
---|
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: |
Collateral Managers Record | Full name of cash collateral manager | LEI, if any | 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? | Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? | — | — | — | — | — |
---|
e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): | ☐
i. Revenue sharing split
☐ ii. Non-revenue sharing split (other than administrative fee) ☐ iii. Administrative fee ☐ iv. Cash collateral reinvestment fee ☐ v. Indemnification fee ☐ vi. Other ☒ 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 |
a. Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) | ☐
a. Rule 10f-3 (17 CFR 270.10f-3)
☐ b. Rule 12d1-1 (17 CFR 270.12d1-1) ☐ c. Rule 15a-4 (17 CFR 270.15a-4) ☐ d. Rule 17a-6 (17 CFR 270.17a-6) ☐ e. Rule 17a-7 (17 CFR 270.17a-7) ☐ f. Rule 17a-8 (17 CFR 270.17a-8) ☐ g. Rule 17e-1 (17 CFR 270.17e-1) ☐ h. Rule 22d-1 (17 CFR 270.22d-1) ☐ i. Rule 23c-1 (17 CFR 270.23c-1) ☒ j. Rule 32a-4 (17 CFR 270.32a-4) ☐ N/A |
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? | ☒ Yes ☐ No |
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? | ☒ Yes ☐ No |
c. Are the fees waived subject to recoupment? | ☒ Yes ☐ No |
d. Were any expenses previously waived recouped during the period? | ☐ Yes ☒ No |
a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund: |
Full name |
SEC file number ( e.g., 801- ) | CRD number | LEI, if any | State, if applicable | Foreign country, if applicable | Was the investment adviser hired during the reporting period? |
---|---|---|---|---|---|---|
Investment Advisers Record: 1 | ||||||
Aberdeen Asset Managers Limited | 801-75074 | 000162309 | 549300EI2QZDOKF0UR93 | UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND | 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: |
Full name |
SEC file number ( e.g., 801- ) | CRD number | LEI, if any | State, if applicable | Foreign country, if applicable | Termination date |
---|---|---|---|---|---|---|
Investment Advisers Terminated Record: 1 | ||||||
Alpine Woods Capital Investors, LLC | 801-55110 | 000112496 | 254900SA7IHKRR912223 | NEW YORK | UNITED STATES OF AMERICA | 2018-05-04 |
c. For each sub-adviser to the Fund, provide the information requested: |
Full name |
SEC file number ( e.g., 801- ) | CRD number | LEI, if any | State, if applicable | Foreign country, if applicable | Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? | Was the sub-adviser hired during the reporting period? | — | — | — | — | — | — | — | — |
---|
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser: |
Full name |
SEC file number ( e.g., 801- ) | CRD number | LEI, if any | State, if applicable | Foreign country, if applicable | Termination date | — | — | — | — | — | — | — |
---|
a. Provide the following information about each person providing transfer agency services to the Fund: |
Full name |
SEC file number ( e.g., 801- ) | LEI, if any | State, if applicable | Foreign country, if applicable | Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? | Is the transfer agent a sub-transfer agent? |
---|---|---|---|---|---|---|
Transfer Agents Record: 1 | ||||||
DST Asset Manager Solutions, Inc. | 84-00896 | 21B7QCD05XOK0YTYOP98 | MASSACHUSETTS | UNITED STATES OF AMERICA | No | No |
b. Has a transfer agent been hired or terminated during the reporting period? | ☐ Yes ☒ No |
a. Provide the following information about each person that provided pricing services to the Fund during the reporting period: |
Pricing Services Record | Full name | LEI, if any, or provide and describe other identifying number | State, if applicable | Foreign country, if applicable | Is the pricing service an affiliated person of the Fund or its investment adviser(s)? |
---|---|---|---|---|---|
#1 | Thomson Reuters Corporation | 549300561UZND4C7B569 | CANADA (FEDERAL LEVEL) | No | |
#2 | ICE Data Services, Inc. | 5493000NQ9LYLDBCTL34 | NEW JERSEY | UNITED STATES OF AMERICA | No |
#3 | Bloomberg L.P. | 549300B56MD0ZC402L06 | NEW YORK | UNITED STATES OF AMERICA | No |
#4 | PricingDirect Inc. | 549300WIC0TOJ7N7GD54 | NEW YORK | UNITED STATES OF AMERICA | No |
#5 | IHS Markit Ltd. | 549300HLPTRASHS0E726 | UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND | No |
b. Was a pricing service hired or terminated during the reporting period? | ☐ Yes ☒ No |
a. Provide the following information about each person that provided custodial services to the Fund during the reporting period: |
Custodians Record | Full name | LEI, if any | State, if applicable | Foreign country, if applicable | Is the custodian an affiliated person of the Fund or its investment adviser(s)? | Is the custodian a sub-custodian? |
Type of custody (describe if "Other") |
---|---|---|---|---|---|---|---|
#1 | Deutsche Bank Aktiengesellschaft (Vienna, Vienna, AT, Branch) | 7LTWFZYICNSX8D621K86 | AUSTRIA | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#2 | The Hongkong and Shanghai Banking Corporation Limited (Sydney, NSW, AU, Branch) | 2HI3YI5320L3RW6NJ957 | AUSTRALIA | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#3 | The Hongkong and Shanghai Banking Corporation Limited (Auckland, Auckland, NZ, Branch) | 2HI3YI5320L3RW6NJ957 | NEW ZEALAND | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#4 | State Street Trust Company Canada | 549300L71XG2CTQ2V827 | CANADA (FEDERAL LEVEL) | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#5 | Deutsche Bank Aktiengesellschaft (Makati City, Metro Manila, PH, Branch) | 7LTWFZYICNSX8D621K86 | PHILIPPINES | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#6 | Bank Handlowy w Warszawie Spolka Akcyjna | XLEZHWWOI4HFQDGL4793 | POLAND | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#7 | Banco Nacional de Mexico, S.A., Integrante del Grupo Financiero Banamex | 2SFFM4FUIE05S37WFU55 | MEXICO | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#8 | Itau CorpBanca | 549300DDPTTIZ06NIV06 | CHILE | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#9 | Deutsche Bank Societa per Azioni | 529900SS7ZWCX82U3W60 | ITALY | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#10 | HSBC Bank Middle East Limited | 549300F99IL9YJDWH369 | UNITED ARAB EMIRATES | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#11 | Nordea Bank AB (Oslo, Oslo, NO, Branch) | 529900ODI3047E2LIV03 | NORWAY | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#12 | Citibank, National Association (Singapore, SG, Branch) | E57ODZWZ7FF32TWEFA76 | SINGAPORE | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#13 | Deutsche Bank Aktiengesellschaft (Mumbai, Maharashtra, IN, Branch) | 7LTWFZYICNSX8D621K86 | INDIA | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#14 | Nordea Bank AB (publ) (Helsinki, Uusimaa, FI, Branch) | 6SCPQ280AIY8EP3XFW53 | FINLAND | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#15 | Deutsche Bank Aktiengesellschaft (Amsterdam, Noord Holland, NL, Branch) | 7LTWFZYICNSX8D621K86 | NETHERLANDS | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#16 | BNP Paribas Securities Services (Athens, Attica, GR, Branch) | 549300WCGB70D06XZS54 | GREECE | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#17 | Citibank, National Association (Sao Paulo, Sao Paulo, BR, Branch) | 579100KKDGKCFFKKF005 | BRAZIL | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#18 | State Street Bank and Trust Company (London, GB, Branch) | 0000000000 | UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#19 | State Street Bank and Trust Company | 571474TGEMMWANRLN572 | MASSACHUSETTS | UNITED STATES OF AMERICA | No | No | Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) |
#20 | Deutsche Bank Aktiengesellschaft (Jakarta, Jakarta, ID, Branch) | 7LTWFZYICNSX8D621K86 | INDONESIA | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#21 | The Hongkong and Shanghai Banking Corporation Limited (Chuo ku, Tokyo, JP, Branch) | 2HI3YI5320L3RW6NJ957 | JAPAN | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#22 | Deutsche Bank (Malaysia) Berhad | 529900DLWFR8HK7DR278 | MALAYSIA | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#23 | Nordea Bank AB (publ) (Stockholm, Stockholm, SE, Branch) | 6SCPQ280AIY8EP3XFW53 | SWEDEN | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#24 | Clearstream Banking S.A. | 549300OL514RA0SXJJ44 | LUXEMBOURG | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#25 | Deutsche Bank Aktiengesellschaft (Jongno-gu, Seoul, KR, Branch) | 7LTWFZYICNSX8D621K86 | KOREA (THE REPUBLIC OF) | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#26 | Nordea Bank Danmark A/S | 549300LX0YIEPRTY0Z32 | DENMARK | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#27 | Credit Suisse (Schweiz) AG | 549300CWR0W0BCS9Q144 | SWITZERLAND | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#28 | State Street Bank International GmbH | ZMHGNT7ZPKZ3UFZ8EO46 | GERMANY | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#29 | FirstRand Bank Limited | ZAYQDKTCATIXF9OQY690 | SOUTH AFRICA | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#30 | Bank Hapoalim B.M. | B6ARUI4946ST4S7WOU88 | ISRAEL | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#31 | Standard Chartered Bank (Taiwan) Limited | 549300QJEO1B92LSHZ06 | TAIWAN (PROVINCE OF CHINA) | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#32 | Bank Polska Kasa Opieki - Spolka Akcyjna | 5493000LKS7B3UTF7H35 | POLAND | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#33 | Standard Chartered Bank (Hong Kong) Limited | X5AV1MBDXGRPX5UGMX13 | HONG KONG | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#34 | Deutsche Bank Aktiengesellschaft (Madrid, Madrid, ES, Branch) | 529900SICIK5OVMVY186 | SPAIN | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#35 | Standard Chartered Bank (Thai) Public Company Limited | 549300O1LQYCQ7G1IM57 | THAILAND | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) | |
#36 | Deutsche Bank Aktiengesellschaft (Sisli, Istanbul, TR, Branch) | 7LTWFZYICNSX8D621K86 | TURKEY | No | Yes | Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7) |
b. Has a custodian been hired or terminated during the reporting period?* | ☐ Yes ☒ No |
a. Provide the following information about each shareholder servicing agent of the Fund: |
Shareholder Servicing Agents Record | Full name | LEI, if any, or provide and describe other identifying number | State, if applicable | Foreign country, if applicable | Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? | Is the shareholder servicing agent a sub-shareholder servicing agent? |
---|---|---|---|---|---|---|
#1 | DST Asset Manager Solutions, Inc. | 21B7QCD05XOK0YTYOP98 | MASSACHUSETTS | UNITED STATES OF AMERICA | No | No |
b. Has a shareholder servicing agent been hired or terminated during the reporting period? | ☐ Yes ☒ No |
a. Provide the following information about each administrator of the Fund: |
Administrators Record | Full name | LEI, if any, or provide and describe other identifying number | State, if applicable | Foreign country, if applicable | Is the administrator an affiliated person of the Fund or its investment adviser(s)? | Is the administrator a sub-administrator? |
---|---|---|---|---|---|---|
#1 | State Street Bank and Trust Company | 571474TGEMMWANRLN572 | MASSACHUSETTS | UNITED STATES OF AMERICA | No | No |
b. Has a third-party administrator been hired or terminated during the reporting period? | ☐ Yes ☒ No |
a. Provide the following information about each affiliated broker-dealer: |
Broker Dealers Record | Full name | SEC file number | CRD number | LEI, if any | State, if applicable | Foreign country, if applicable | Total commissions paid to the affiliated broker-dealer for the reporting period |
---|---|---|---|---|---|---|---|
#1 | Aberdeen Fund Distributors, LLC | 8-67799 | 000146230 | 2138007O8Z7FY13LG555 | PENNSYLVANIA | UNITED STATES OF AMERICA | 0.00000000 |
#2 | ALPS Distributors, Inc. | 8-34626 | 000016853 | 0000000000 | COLORADO | UNITED STATES OF AMERICA | 0.00000000 |
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 | Full name | SEC file number | CRD number | LEI, if any | State, if applicable | Foreign country, if applicable | Gross commissions paid by the Fund for the reporting period |
---|---|---|---|---|---|---|---|
#1 | Morgan Stanley & Co. LLC | 8-15869 | 000008209 | 9R7GPTSO7KV3UQJZQ078 | NEW YORK | UNITED STATES OF AMERICA | 34,789.98000000 |
#2 | Mizuho Securities USA LLC | 8-37710 | 000019647 | 7TK5RJIZDFROZCA6XF66 | NEW YORK | UNITED STATES OF AMERICA | 5,093.28000000 |
#3 | Credit Suisse Securities (USA) LLC | 8-422 | 000000816 | 1V8Y6QCX6YMJ2OELII46 | NEW YORK | UNITED STATES OF AMERICA | 17,342.69000000 |
#4 | Barclays Capital Inc. | 8-41342 | 000019714 | AC28XWWI3WIBK2824319 | NEW YORK | UNITED STATES OF AMERICA | 24,712.12000000 |
#5 | JPMorgan Chase & Co. | 8-35008 | 000000079 | 8I5DZWZKVSZI1NUHU748 | NEW YORK | UNITED STATES OF AMERICA | 13,853.16000000 |
#6 | UBS Securities LLC | 8-22651 | 000007654 | T6FIZBDPKLYJKFCRVK44 | NEW YORK | UNITED STATES OF AMERICA | 6,930.41000000 |
#7 | MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED | 8-7221 | 000007691 | 8NAV47T0Y26Q87Y0QP81 | NEW YORK | UNITED STATES OF AMERICA | 4,474.73000000 |
#8 | Citigroup Global Markets Inc. | 8-8177 | 000007059 | MBNUM2BPBDO7JBLYG310 | NEW YORK | UNITED STATES OF AMERICA | 16,820.29000000 |
#9 | Instinet, LLC | 8-23669 | 000007897 | 549300MGMN3RKMU8FT57 | NEW YORK | UNITED STATES OF AMERICA | 5,470.86000000 |
#10 | RBC Capital Markets, LLC | 8-45411 | 000031194 | 549300LCO2FLSSVFFR64 | NEW YORK | UNITED STATES OF AMERICA | 8,984.28000000 |
b. Aggregate brokerage commissions paid by Fund during the reporting period: | 177,756.90000000 |
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 | Full name | SEC file number | CRD number | LEI, if any | State, if applicable | Foreign country, if applicable | Total value of purchases and sales (excluding maturing securities) with Fund |
---|---|---|---|---|---|---|---|
#1 | State Street Bank and Trust Company | N/A | N/A | 571474TGEMMWANRLN572 | MASSACHUSETTS | UNITED STATES OF AMERICA | 58,327,050.91000000 |
#2 | MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED | 8-7221 | 000007691 | 8NAV47T0Y26Q87Y0QP81 | NEW YORK | UNITED STATES OF AMERICA | 9,789,448.27000000 |
b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period: | 68,116,499.18000000 |
a. 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)? | ☐ Yes ☒ No |
a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period | 145,464,476.03000000 |
b. Provide the money market fund's daily average net assets during the reporting period |
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? | ☐ Yes ☐ No |
Instruction. For any security issued by the Fund that is not listed on a securities exchange but that has a ticker symbol, provide that ticker symbol.
Indicate by checking below which of the following securities have been issued by the Registrant. Indicate all that apply. |
Security Issued by Registrants Record | Type of security (describe if "Other") | Title of class | |
---|---|---|---|
#1 | Common stock | ABERDEEN GLOBAL DYNAMIC DIVIDEND FUND | |
Common Record | Exchange where listed | Ticker symbol | |
#1 | NEW YORK STOCK EXCHANGE, INC. | AGD | |
Instruction. For Item D.2.c, the "percentage of participation in primary rights offering" is calculated as the percentage of subscriptions exercised during the primary rights offering relative to the amount of securities available for primary subscription. |
a. Did the Fund make a rights offering with respect to any type of security during the reporting period? | ☐ Yes ☒ No |
a. Did the Fund make a secondary offering during the reporting period? | ☐ Yes ☒ No |
a. Did the Fund repurchase any outstanding securities issued by the Fund during the reporting period? | ☐ Yes ☒ No |
Instruction. The term "long-term debt" means debt with a period of time from date of initial issuance to maturity of one year or greater. |
a. Were any issues of the Fund's long-term debt in default at the close of the reporting period with respect to the payment of principal, interest, or amortization? | ☐ Yes ☒ No |
Instruction. The term "dividends in arrears" means dividends that have not been declared by the board of directors or other governing body of the Fund at the end of each relevant dividend period set forth in the constituent instruments establishing the rights of the stockholders. |
a. Were any accumulated dividends in arrears on securities issued by the Fund at the close of the reporting period? | ☐ Yes ☒ No |
a. Have the terms of any constituent instruments defining the rights of the holders of any class of the Registrant's securities been materially modified? | ☐ Yes ☒ No |
Instruction. Base the percentage on amounts incurred during the reporting period |
a. Provide the Fund's advisory fee as of the end of the reporting period as percentage of net assets: | 1.00000000 |
a. Provide the Fund's net annual operating expenses as of the end of the reporting period (net of any waivers or reimbursements) as a percentage of net assets: | 1.19000000 |
Instruction. Respond to this item with respect to common stock issued by the Registrant only. |
a. Market price per share at end of reporting period: | 9.25000000 |
Instruction. Respond to this item with respect to common stock issued by the Registrant only. |
a. Net asset value per share at end of reporting period: | 10.80000000 |
a. 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: | ☐
i. Legal proceedings
☐ ii. Provision of financial support ☒ iii. Independent public accountant's report on internal control (management investment companies other than small business investment companies only) ☐ iv. Change in accounting principles and practices ☐ v. Information required to be filed pursuant to exemptive orders ☐ vi. Other information required to be included as an attachment pursuant to Commission rules and regulations |
a. Attachments to be filed by closed-end management investment companies and small business investment companies. 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: | ☒
i. Material amendments to organizational documents
☐ ii. Instruments defining the rights of the holders of any new or amended class of securities ☒ iii. New or amended investment advisory contracts ☒ iv. Information called for by Item 405 of Regulation S-K ☐ v. Code of ethics (small business investment companies only) |
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. |
Instructions. 7. Item G.1.b.i. Material amendments to organizational documents. Provide copies of all material amendments to the Registrant's charters, by-laws, or other similar organizational documents that occurred during the reporting period. 8. Item G.1.b.ii. Instruments defining the rights of the holders of any new or amended class of securities. Provide copies of all constituent instruments defining the rights of the holders of any new or amended class of securities for the current reporting period. If the Registrant has issued a new class of securities other than short-term paper, furnish a description of the class called for by the applicable item of Form N-2. If the constituent instruments defining the rights of the holders of any class of the Registrant's securities have been materially modified during the reporting period, give the title of the class involved and state briefly the general effect of the modification upon the rights of the holders of such securities. 9. Item G.1.b.iii. New or amended investment advisory contracts. Provide copies of any new or amended investment advisory contracts that became effective during the reporting period. 10. Item G.1.b.iv. Information called for by Item 405 of Regulation S-K. Provide the information called for by Item 405 of Regulation S-K concerning failure of certain closed-end management investment company and small business investment company shareholders to file certain ownership reports. 11. Item G.1.b.v. Code of ethics (small business investment companies only). (a) (1) Disclose whether, as of the end of the period covered by the report, the Registrant has adopted a code of ethics that applies to the Registrant's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the Registrant or a third party. If the Registrant has not adopted such a code of ethics, explain why it has not done so. (2) For purposes of this instruction, the term "code of ethics" means written standards that are reasonably designed to deter wrongdoing and to promote: (i) honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships; (ii) full, fair, accurate, timely, and understandable disclosure in reports and documents that a Registrant files with, or submits to, the Commission and in other public communications made by the Registrant; (iii) compliance with applicable governmental laws, rules, and regulations; (iv) the prompt internal reporting of violations of the code to an appropriate person or persons identified in the code; and (v) accountability for adherence to the code. (3) The Registrant must briefly describe the nature of any amendment, during the period covered by the report, to a provision of its code of ethics that applies to the Registrant's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the Registrant or a third party, and that relates to any element of the code of ethics definition enumerated in paragraph (a)(2) of this instruction. The Registrant must file a copy of any such amendment as an exhibit to this report on Form N-CEN, unless the Registrant has elected to satisfy paragraph (a)(6) of this instruction by posting its code of ethics on its website pursuant to paragraph (a)(6)(ii) of this Instruction, or by undertaking to provide its code of ethics to any person without charge, upon request, pursuant to paragraph (a)(6)(iii) of this instruction. (4) If the Registrant has, during the period covered by the report, granted a waiver, including an implicit waiver, from a provision of the code of ethics to the Registrant's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the Registrant or a third party, that relates to one or more of the items set forth in paragraph (a)(2) of this instruction, the Registrant must briefly describe the nature of the waiver, the name of the person to whom the waiver was granted, and the date of the waiver. (5) If the Registrant intends to satisfy the disclosure requirement under paragraph (a)(3) or (4) of this instruction regarding an amendment to, or a waiver from, a provision of its code of ethics that applies to the Registrant's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions and that relates to any element of the code of ethics definition enumerated in paragraph (a)(2) of this instruction by posting such information on its Internet website, disclose the Registrant's Internet address and such intention. (6) The Registrant must: (i) file with the Commission a copy of its code of ethics that applies to the Registrant's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, as an exhibit to its report on this Form N-CEN; (ii) post the text of such code of ethics on its Internet website and disclose, in its most recent report on this Form N-CEN, its Internet address and the fact that it has posted such code of ethics on its Internet website; or (iii) undertake in its most recent report on this Form N-CEN to provide to any person without charge, upon request, a copy of such code of ethics and explain the manner in which such request may be made. (7) A Registrant may have separate codes of ethics for different types of officers. Furthermore, a "code of ethics" within the meaning of paragraph (a)(2) of this instruction may be a portion of a broader document that addresses additional topics or that applies to more persons than those specified in paragraph (a)(1) of this instruction. In satisfying the requirements of paragraph (a)(6) of this instruction, a Registrant need only file, post, or provide the portions of a broader document that constitutes a "code of ethics" as defined in paragraph (a)(2) of this instruction and that apply to the persons specified in paragraph (a)(1) of this instruction. (8) If a Registrant elects to satisfy paragraph (a)(6) of this instruction by posting its code of ethics on its Internet website pursuant to paragraph (a)(6)(ii), the code of ethics must remain accessible on its website for as long as the Registrant remains subject to the requirements of this instruction and chooses to comply with this instruction by posting its code on its Internet website pursuant to paragraph (a)(6)(ii). (9) The Registrant does not need to provide any information pursuant to paragraphs (a)(3) and (4) of this instruction if it discloses the required information on its Internet website within five business days following the date of the amendment or waiver and the Registrant has disclosed in its most recently filed report on this Form N-CEN its Internet website address and intention to provide disclosure in this manner. If the amendment or waiver occurs on a Saturday, Sunday, or holiday on which the Commission is not open for business, then the five business day period shall begin to run on and include the first business day thereafter. If the Registrant elects to disclose this information through its website, such information must remain available on the website for at least a 12-month period. The Registrant must retain the information for a period of not less than six years following the end of the fiscal year in which the amendment or waiver occurred. Upon request, the Registrant must furnish to the Commission or its staff a copy of any or all information retained pursuant to this requirement. (10) The Registrant does not need to disclose technical, administrative, or other non-substantive amendments to its code of ethics. (11) For purposes of this instruction: (i) the term "waiver" means the approval by the Registrant of a material departure from a provision of the code of ethics; and (ii) the term "implicit waiver" means the Registrant's failure to take action within a reasonable period of time regarding a material departure from a provision of the code of ethics that has been made known to an executive officer, as defined in rule 3b-7 under the Exchange Act (17 CFR 240.3b-7), of the Registrant. (b) (1) Disclose that the Registrant's board of directors has determined that the Registrant either: (i) has at least one audit committee financial expert serving on its audit committee; or (ii) does not have an audit committee financial expert serving on its audit committee. (2) If the Registrant provides the disclosure required by paragraph (b)(1)(i) of this instruction, it must disclose the name of the audit committee financial expert and whether that person is "independent." In order to be considered "independent" for purposes of this instruction, a member of an audit committee may not, other than in his or her capacity as a member of the audit committee, the board of directors, or any other board committee: (i) accept directly or indirectly any consulting, advisory, or other compensatory fee from the issuer; or (ii) be an "interested person" of the investment company as defined in Section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19)). (3) If the Registrant provides the disclosure required by paragraph (b)(1)(ii) of this instruction, it must explain why it does not have an audit committee financial expert. (4) If the Registrant's board of directors has determined that the Registrant has more than one audit committee financial expert serving on its audit committee, the Registrant may, but is not required to, disclose the names of those additional persons. A Registrant choosing to identify such persons must indicate whether they are independent pursuant to paragraph (b)(2) of this instruction. (5) For purposes of this instruction, an "audit committee financial expert" means a person who has the following attributes: (i) an understanding of generally accepted accounting principles and financial statements; (ii) the ability to assess the general application of such principles in connection with the accounting for estimates, accruals, and reserves; (iii) experience preparing, auditing, analyzing, or evaluating financial statements that present a breadth and level of complexity of accounting issues that are generally comparable to the breadth and complexity of issues that can reasonably be expected to be raised by the Registrant's financial statements, or experience actively supervising one or more persons engaged in such activities; (iv) an understanding of internal controls and procedures for financial reporting; and (v) an understanding of audit committee functions. (6) A person shall have acquired such attributes through: (i) education and experience as a principal financial officer, principal accounting officer, controller, public accountant, or auditor or experience in one or more positions that involve the performance of similar functions; (ii) experience actively supervising a principal financial officer, principal accounting officer, controller, public accountant, auditor, or person performing similar functions; (iii) experience overseeing or assessing the performance of companies or public accountants with respect to the preparation, auditing, or evaluation of financial statements; or (iv) other relevant experience. (7) (i) A person who is determined to be an audit committee financial expert will not be deemed an "expert" for any purpose, including without limitation for purposes of Section 11 of the Securities Act (15 U.S.C. 77k), as a result of being designated or identified as an audit committee financial expert pursuant to this instruction; (ii) the designation or identification of a person as an audit committee financial expert pursuant to this instruction does not impose on such person any duties, obligations, or liability that are greater than the duties, obligations, and liability imposed on such person as a member of the audit committee and board of directors in the absence of such designation or identification; (iii) the designation or identification of a person as an audit committee financial expert pursuant to this instruction does not affect the duties, obligations, or liability of any other member of the audit committee or board of directors. (8) If a person qualifies as an audit committee financial expert by means of having held a position described in paragraph (b)(6)(iv) of this Instruction, the Registrant shall provide a brief listing of that person's relevant experience. |
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 | ABERDEEN GLOBAL DYNAMIC DIVIDEND FUND |
Date | 2019-01-14 |
Signature | Sharon Ferrari |
Title | Senior Manager |
STATE OF DELAWARE
CERTIFICATE OF AMENDMENT
TO CERTIFICATE OF TRUST
Pursuant to Title 12, Section 3810(b) of the Delaware
Statutory Trust Act, the undersigned Trust executed
the following Certificate of Amendment:
1. Name of Statutory Trust: Alpine Global Dynamic
Dividend Fund
2. The Certificate of
Amendment to the
Certificate of Trust
is hereby amended
as follows: The new
name of the entity is:
Aberdeen Global
Dynamic Dividend
Fund
[set forth amendment(s)]
3. (Please complete with either upon filing or it may
be a future effective date that is within 90 days of the
file date) This Certificate of Amendments shall be
effective .
IN WITNESS WHEREOF, the undersigned have
executed this Certificate on the 16th day of April, 2018
A.D.
By: /s/ Samuel Lieber Trustee Name: Samuel Lieber Type or Print |
Information Classification: Limited Access
Information Classification: Limited Access
AGD Exhibit G.1.b.iv
Aberdeen Global Dynamic Dividend
Fund (the "Fund") A Form 3 for the
below individual (an Officer of the
Fund) was not filed within the
required regulatory timeframe:
Martin Connaghan
Information Classification: Limited Access
Information Classification: Limited Access
INVESTMENT ADVISORY AGREEMENT
THIS AGREEMENT is made and entered into as of the
4th day of May, 2018 by and between ABERDEEN
GLOBAL DYNAMIC DIVIDEND FUND (the "Fund"),
a Delaware statutory trust, and ABERDEEN ASSET
MANAGERS LIMITED (the "Adviser"), a United
Kingdom corporation registered under the Investment
Advisers Act of 1940, as amended (the "Advisers Act").
W I T N E S S E T H:
WHEREAS, the Fund is registered with the Securities
and Exchange Commission (the "SEC") as an open-end
management investment company under the Investment
Company Act of 1940, as amended (the "1940 Act");
WHEREAS, the Fund desires to retain the Adviser to
furnish certain investment advisory services, as
described herein, with respect to the Fund; and
WHEREAS, the Adviser represents that it is willing and
possesses legal authority to render such services subject
to the terms and conditions set forth in this Agreement,
NOW, THEREFORE, the Fund and the Adviser do
mutually agree and promise as follows:
1. Appointment as Adviser. The Fund hereby appoints
the Adviser to act as investment adviser to the Fund
subject to the terms and conditions set forth in this
Agreement. The Adviser hereby accepts such
appointment and agrees to furnish the services
hereinafter described for the compensation provided for
in this Agreement.
2. Duties of Adviser.
(a) Investment Management Services.
(i) Subject to the supervision of the Fund's Board of
Trustees (and except as otherwise permitted under the
terms of any exemptive relief obtained by the Adviser
from the SEC, or by rule or regulation), the Adviser will
provide, or arrange for the provision of, a continuous
investment program and overall investment strategies for
the Fund, including investment research and
management with respect to all securities and
investments and cash equivalents in the Fund. The
Adviser will determine, or arrange for others to
determine, from time to time what securities and other
investments will be purchased, retained or sold by the
Fund and will implement, or arrange for others to
implement, such determinations through the placement,
in the name of the Fund, of orders for the execution of
portfolio transactions with or through such brokers or
dealers as may be so selected. The Adviser will provide,
or arrange for the provision of, the services under this
Agreement in accordance with the stated investment
policies and restrictions of the Fund as set forth in the
Fund's registration statement, as supplemented or
amended from time to time (collectively referred to
hereinafter as the "Prospectus") and subject to the
directions of the Fund's Board of Trustees. With respect
to foreign securities, at its own expense, the Adviser
may obtain statistical and other factual information and
advice regarding economic factors and trends from its
foreign affiliates, and may obtain investment services
from the investment advisory personnel of its affiliates
located throughout the world to the extent permitted
under interpretations of the federal securities laws.
(ii) Subject to the provisions of this Agreement and the
1940 Act and any exemptions thereto, the Adviser is
authorized to appoint one or more qualified subadvisers
(each a "Subadviser") to provide the Fund with certain
services required by this Agreement. Each Subadviser
shall have such
investment discretion and shall make all determinations
with respect to the investment of the Fund's assets as
shall be assigned to that Subadviser by the Adviser and
the purchase and sale of portfolio securities with respect
to those assets and shall take such steps as may be
necessary to implement its decisions. The Adviser shall
not be responsible or liable for the investment merits of
any decision by a Subadviser to purchase, hold, or sell a
security for the Fund.
(iii) Subject to the supervision and direction of the
Trustees, the Adviser shall (i) have overall supervisory
responsibility for the general management and
investment of the Fund's assets; (ii) determine the
allocation of assets among the Subadvisers, if any; and
(iii) have full investment discretion to make all
determinations with respect to the investment of Fund
assets not otherwise assigned to a Subadviser.
(iv) The Adviser shall research and evaluate each
Subadviser, if any, including (i) performing initial due
diligence on prospective Subadvisers and monitoring
each Subadviser's ongoing performance; (ii)
communicating performance expectations and
evaluations to the Subadvisers; and (iii) recommending
to the Fund's Board of Trustees whether a Subadviser's
contract should be renewed, modified or terminated. The
Adviser shall also recommend changes or additions to
the Subadvisers and shall compensate the Subadvisers.
(v) The Adviser shall provide to the Fund's Board of
Trustees such periodic reports concerning the Fund's
business and investments as the Board of Trustees shall
reasonably request.
(b) Compliance with Applicable Laws and Governing
Documents. In the performance of its duties and
obligations under this Agreement, the Adviser shall act
in conformity with the Fund's Agreement and
Declaration of Trust, as from time to time amended
and/or restated, and By-Laws, as from time to time
amended and/or restated, and the Prospectus and with
the instructions and directions received from the
Trustees of the Fund and will conform to and comply
with the requirements of the 1940 Act, the Internal
Revenue Code of 1986, as amended (the "Code")
(including the requirements for qualification as a
regulated investment company) and all other applicable
federal and state laws and regulations.
The Adviser acknowledges and agrees that subject to the
supervision and directions of the Fund's Board of
Trustees, it shall be responsible for compliance with all
disclosure requirements under all applicable federal and
state laws and regulations relating to the Fund,
including, without limitation, the 1940 Act, and the rules
and regulations thereunder, except that the Adviser shall
not have liability in connection with information
furnished by a Subadviser, an independent Trustee,
independent Trustees' counsel or any other unaffiliated
third party to the Fund or to the Adviser.
(c) Consistent Standards. It is recognized that the
Adviser will perform various investment management
and administrative services for entities other than the
Fund; in connection with providing such services, the
Adviser agrees to exercise the same skill and care in
performing its services under this Agreement as the
Adviser exercises in performing similar services with
respect to the other fiduciary accounts for which the
Adviser has investment responsibilities.
(d) Brokerage. The Adviser is authorized, subject to the
supervision of the Fund's Board of Trustees, (1) to
establish and maintain accounts on behalf of the Fund
with, and to place orders for the purchase and sale of
assets not allocated to a Subadviser, with or through,
such persons, brokers or dealers ("brokers") as the
Adviser may select, and (2) to negotiate commissions to
be paid on such transactions. In the selection of such
brokers and the placing of such orders, the Adviser shall
seek to obtain for the Fund the most favorable price and
execution available, except to the extent the Adviser may
be permitted to pay higher brokerage commissions for
brokerage and research services, as provided below. In
using its reasonable efforts to obtain the most favorable
price and execution available, the Adviser, bearing in
mind
the Fund's best interests at all times, shall consider all
factors it deems relevant, including price, the size of the
transaction, the nature of the market for the security, the
amount of the commission, if any, the timing of the
transaction, market prices and trends, the reputation,
experience and financial stability of the broker involved,
and the quality of service rendered by the broker in other
transactions. Subject to such policies as the Trustees
may determine, the Adviser shall not be deemed to have
acted unlawfully or to have breached any duty created by
this Agreement or otherwise solely by reason of its
having caused the Fund to pay a broker that provides
brokerage and research services (within the meaning of
Section 28(e) of the Securities Exchange Act of 1934, as
amended) to the Adviser an amount of commission for
effecting the Fund's investment transaction in excess of
the amount of commission that another broker would
have charged for effecting that transaction, if, but only
if, the Adviser determines in good faith that such
commission was reasonable in relation to the value of
the brokerage and research services provided by such
broker or dealer, viewed in terms of either that particular
transaction or the overall responsibilities of the Adviser
with respect to the accounts as to which it exercises
investment discretion.
It is recognized that the services provided by such
brokers may be useful to the Adviser in connection with
the Adviser's services to other clients. On occasions
when the Adviser deems the purchase or sale of a
security to be in the best interests of the Fund as well as
other clients of the Adviser, the Adviser, to the extent
permitted by applicable laws and regulations, may, but
shall be under no obligation to, aggregate the securities
to be sold or purchased in order to obtain the most
favorable price or lower brokerage commissions and
efficient execution. In such event, allocation of securities
so sold or purchased, as well as the expenses incurred in
the transaction, will be made by the Adviser in the
manner the Adviser considers to be the most equitable
and consistent with its fiduciary obligations to the Fund
and to such other clients.
(e) Securities Transactions. The Adviser will not
purchase securities or other instruments from or sell
securities or other instruments to the Fund; provided,
however, the Adviser may purchase securities or other
instruments from or sell securities or other instruments
to the Fund if such transaction is permissible under
applicable laws and regulations, including, without
limitation, the 1940 Act, the Advisers Act and the rules
and regulations promulgated thereunder or any
exemption therefrom.
The Adviser agrees to observe and comply with Rule
17j-1 under the 1940 Act and the Fund's Code of Ethics,
as the same may be amended from time to time.
(f) Books and Records. In accordance with the 1940 Act
and the rules and regulations promulgated thereunder,
the Adviser shall maintain separate books and detailed
records of all matters pertaining to the Fund (the "Fund's
Books and Records"), including, without limitation, a
daily ledger of such assets and liabilities relating thereto
and brokerage and other records of all securities
transactions. The Adviser acknowledges that the Fund's
Books and Records are property of the Fund. In addition,
the Fund's Books and Records shall be available to the
Fund at any time upon request and shall be available for
electronic transmission without delay to the Fund during
any day that the Fund is open for business.
(g) Voting of Proxies. The Fund grants the Adviser the
discretionary authority to exercise voting rights with
respect to the securities and other investments in the
Fund and authorizes the Adviser to delegate further such
discretionary authority to a Subadviser or a designee.
The Adviser, including without limitation its designee,
shall have the power to vote, either in person or by
proxy, all securities in which the Fund may be invested
from time to time, and shall not be required to seek or
take instructions from the Fund or take any action with
respect thereto. If the Adviser and Subadviser, if any,
have invested the Fund's assets in the same security, the
Adviser and such other entity will each have the power
to vote its pro rata share of the Fund's security.
The Adviser will establish, or will require a Subadviser
to whom the Adviser delegates proxy voting to establish,
a written procedure for proxy voting in compliance with
current applicable rules and regulations, including but
not limited to Rule 30b1-4 under the 1940 Act. The
Adviser will adopt procedures and establish a process, or
will require a Subadviser to whom the Adviser delegates
proxy voting to adopt procedures and establish a
process, for the timely distribution of the Adviser's and
Subadviser's voting record with respect to the Fund's
securities and other information within the possession or
control of the Adviser or Subadviser necessary for the
Fund to complete information required by any required
filings under Federal securities laws, including but not
limited to Form N-2 under the 1940 Act and the
Securities Act of 1933, as amended (the "Securities
Act"), Form N-PX under the 1940 Act, Form N-Q under
the 1940 Act, and Form N-CSR under the Sarbanes-
Oxley Act of 2002, as amended, respectively.
3. Expenses. During the term of this Agreement, the
Adviser will pay all expenses incurred by it in
connection with its activities under this Agreement other
than the cost of securities, commodities and other
investments (including brokerage commissions and other
transaction charges, if any) purchased for the Fund. The
Adviser shall, at its sole expense, employ or associate
itself with such persons as it believes to be fitted to assist
it in the execution of its duties under this Agreement.
The Adviser shall be responsible for the compensation of
the officers of the Fund and the Trustees of the Fund
who are "interested persons" (as defined in the 1940
Act) of the Adviser.
It is understood that the Fund will pay all of its own
expenses, including, without limitation, (1) all charges
and expenses of any custodian or depository appointed
by the Fund for the safekeeping of its cash, securities
and other assets; (2) all charges and expenses paid to any
administrator appointed by the Fund to provide
administrative or compliance services; (3) the charges
and expenses of any transfer agents and registrars
appointed by the Fund; (4) the charges and expenses of
independent certified public accountants and of general
ledger accounting and internal reporting services for the
Fund; (5) the charges and expenses of dividend and
capital gain distributions; (6) the compensation and
expenses of Trustees of the Fund who are not "interested
persons" of the Adviser; (7) brokerage commissions and
issue and transfer taxes chargeable to the Fund in
connection with securities transactions to which the
Fund is a party; (8) all taxes and fees payable by the
Fund to Federal, State or other governmental agencies;
(9) the cost of stock certificates representing shares of
the Fund; (10) all expenses of shareholders' and
Trustees' meetings and of preparing, printing and
distributing Prospectuses, reports and notices to
shareholders and regulatory authorities; (11) charges and
expenses of legal counsel for the Fund in connection
with legal matters relating to the Fund, including without
limitation, legal services rendered in connection with the
Fund's existence, financial structure and relations with
its shareholders, and legal counsel to the independent
Trustees; (12) insurance and bonding premiums; (13)
association membership dues; (14) bookkeeping and the
costs of calculating the net asset value of shares of the
Fund; (15) expenses relating to the issuance, registration
and qualification of the Fund's shares; (16) operational
and organizational expenses of the Fund; (17) payment
of portfolio pricing to a pricing agent, if any; (18)
litigation and indemnification expenses and other
extraordinary expenses not incurred in the ordinary
course of business, and (19) certain expenses as set forth
in the relevant subadvisory agreements.
4. Compensation.
In consideration of the Adviser performing its
obligations hereunder, the Fund will pay to the Adviser a
monthly fee computed at an annual rate of 1% of the
average daily net assets of the Fund.
5. Representations and Warranties of Adviser. The
Adviser represents and warrants to the Fund as follows:
(a) The Adviser is registered as an investment adviser
under the Advisers Act;
(b) The Adviser is a corporation duly organized, validly
existing and in good standing under the laws of the State
of Delaware with the power to own and possess its assets
and carry on its business as it is now being conducted;
(c) The execution, delivery and performance by the
Adviser of this Agreement are within the Adviser's
powers and have been duly authorized by all necessary
action on the part of its shareholders and/or directors,
and no action by or in respect of, or filing with, any
governmental body, agency or official is required on the
part of the Adviser for the execution, delivery and
performance by the Adviser of this Agreement, and the
execution, delivery and performance by the Adviser of
this Agreement do not contravene or constitute a default
under (i) any provision of applicable law, rule or
regulation; (ii) the Adviser's governing instruments; or
(iii) any agreement, judgment, injunction, order, decree
or other instrument binding upon the Adviser; and
(d) The Form ADV of the Adviser provided to the Fund
is a true and complete copy of the form, including that
part or parts of the Form ADV filed with the SEC, that
part or parts maintained in the records of the Adviser,
and/or that part or parts provided or offered to clients, in
each case as required under the Advisers Act and rules
thereunder, and the information contained in such Form
ADV is accurate and complete in all material respects
and does not omit to state any material fact necessary in
order to make the statements made, in light of the
circumstances under which they were made, not
misleading.
6. Survival of Representations and Warranties; Duty to
Update Information. All representations and warranties
made by the Adviser pursuant to Section 5 shall survive
for the duration of this Agreement and the parties hereto
shall promptly notify each other in writing upon
becoming aware that any of the foregoing
representations and warranties are no longer true.
7. Liability and Indemnification.
(a) Liability. In the absence of willful misfeasance, bad
faith or gross negligence on the part of the Adviser or a
reckless disregard of its duties hereunder, the Adviser
shall not be subject to any liability to the Fund, for any
act or omission in the case of, or connected with,
rendering services hereunder or for any losses that may
be sustained in the purchase, holding or sale of Fund
assets; provided, however, that nothing herein shall
relieve the Adviser from any of its obligations under
applicable law, including, without limitation, the federal
and state securities laws.
(b) Indemnification. The Adviser shall indemnify the
Fund and its officers and Trustees, for any liability and
expenses, including attorneys' fees, which may be
sustained as a result of the Adviser's willful
misfeasance, bad faith, gross negligence, reckless
disregard of its duties hereunder or violation of
applicable law, including, without limitation, the federal
and state securities laws.
8. Duration and Termination.
(a) Duration. Unless sooner terminated, this Agreement
shall continue for an initial period of no more than two
years, and thereafter shall continue automatically for
successive annual periods with respect to the Fund;
provided that such continuance is specifically approved
at least annually in the manner required by the 1940 Act.
(b) Termination. Notwithstanding whatever may be
provided herein to the contrary, this Agreement may be
terminated at any time, without payment of any penalty
by vote of a majority of the Fund's Board of Trustees,
or, with respect to the Fund, by "vote of a majority of the
outstanding voting
securities" (as defined in the 1940 Act) of the Fund, or
by the Adviser, in each case, upon not less than sixty
(60) days' written notice to the other party.
This Agreement shall not be assigned (as such term is
defined in the 1940 Act) and shall terminate
automatically in the event of its assignment.
9. Services Not Exclusive. The services furnished by the
Adviser hereunder are not to be deemed exclusive, and
the Adviser shall be free to furnish similar services to
others so long as its services under this Agreement are
not impaired thereby. It is understood that the action
taken by the Adviser under this Agreement may differ
from the advice given or the timing or nature of action
taken with respect to other clients of the Adviser, and
that a transaction in a specific security may not be
accomplished for all clients of the Adviser at the same
time or at the same price.
10. Amendment. This Agreement may be amended by
mutual consent of the parties, provided that the terms of
each such amendment shall be in writing and approved
in the manner required by the 1940 Act.
11. Confidentiality. Subject to the duties of the Adviser
and the Fund to comply with applicable law, including
any demand of any regulatory or taxing authority having
jurisdiction, the parties hereto shall treat as confidential
all information pertaining to the Fund and the actions of
the Adviser and the Fund in respect thereof.
12. Jurisdiction. This Agreement shall be governed by
and construed to be in accordance with substantive laws
of the State of Delaware without reference to choice of
law principles thereof and in accordance with the 1940
Act. In the case of any conflict, the 1940 Act shall
control. Any legal suit, action or proceeding related to,
arising out of or concerning this Agreement shall be
brought only in the U.S. District Court for the District of
Delaware, or if such action may not be brought in that
court, then such action shall be brought in the Court of
Chancery of the State of Delaware (the "Chosen
Courts"). Each party consents to jurisdiction in the
Chosen Courts; (b) waives any objection to venue in
each Chosen Court and (c) waives any objection that
either Chosen Court is an inconvenient forum.
13. Counterparts. This Agreement may be executed in
one or more counterparts, each of which shall be deemed
an original, and all of which shall together constitute one
and the same instrument.
14. Certain Definitions. For the purposes of this
Agreement, "interested person," "affiliated person,"
"assignment" shall have their respective meanings as set
forth in the 1940 Act, subject, however, to such
exemptions as may be granted by the SEC.
15. Captions. The captions herein are included for
convenience of reference only and shall be ignored in the
construction or interpretation hereof.
16. Severability. If any provision of this Agreement shall
be held or made invalid by a court decision or applicable
law, the remainder of the Agreement shall not be
affected adversely and shall remain in full force and
effect.
17. No Third-Party Beneficiaries. This Agreement does
not, and is not intended to, create any third-party
beneficiary or otherwise confer any rights, privileges,
claims or remedies upon any person other than the
parties and their respective successors and permitted
assigns.
18. Force Majeure. Notwithstanding any other provision
of this Agreement, the Adviser shall not be liable for any
losses caused directly or indirectly, whether in whole or
in part, by circumstances
beyond its reasonable control, including, without
limitation, government restrictions, exchange or market
rulings, suspensions of trading, acts of civil or military
authority, national emergencies, riots, terrorism, war or
such event of similar nature, labor difficulties, non-
performance by a third party not hired or otherwise
selected by it to provide services in connection with this
Agreement, natural disaster, casualty, elements of
nature, fires, earthquakes, floods, or other catastrophes,
acts of God, mechanical breakdowns, or malfunctions,
failure or disruption of utilities, communications,
computer or information technology (including, without
limitation, hardware or software), internet, firewalls,
encryptions systems, security devices, or power supply;
provided that the Adviser shall maintain disaster
recovery, business continuity and cybersecurity
procedures in effect consistent with those of similar
registered investment advisers to mutual funds.
[The remainder of this page is intentionally left blank.]
I
N
W
I
T
N
E
S
S
W
H
E
R
E
O
F
,
t
h
e
p
a
r
t
i
e
s
h
e
r
e
t
o
h
a
v
e
e
x
e
c
u
t
e
d
t
h
i
s
A
g
r
e
e
m
e
n
t
o
n
t
h
e
d
a
y
a
n
d
y
e
a
r
f
i
r
s
t
w
r
i
t
t
e
n
a
b
o
v
e
.
A
B
E
R
D
E
E
N
G
L
O
B
A
L
D
Y
N
A
M
I
C
D
I
V
I
D
E
N
D
F
U
N
D
B
y
:
/
s
/
L
u
c
i
a
S
i
t
a
r
N
a
m
e
:
L
u
c
i
a
S
i
t
a
r
T
i
t
l
e
:
V
.
P
.
A
B
E
R
D
E
E
N
A
S
S
E
T
M
A
N
A
G
E
R
S
L
I
M
I
T
E
D
B
y
:
/
s
/
G
o
r
d
o
n
B
r
o
u
g
h
N
a
m
e
:
G
o
r
d
o
n
B
r
o
u
g
h
T
i
t
l
e
:
A
u
t
h
o
r
i
s
e
d
S
i
g
n
a
t
o
r
y
Information Classification: Limited Access
Information Classification: Limited Access
Report of Independent Registered Public
Accounting Firm
To the Shareholders and Board of Trustees of
Aberdeen Global Dynamic Dividend Fund:
In planning and performing our audit of the financial
statements of Aberdeen Global Dynamic Dividend Fund,
(formerly, Alpine Global Dynamic Dividend Fund) (the
"Fund") as of and for the year ended October 31, 2018,
in accordance with the standards of the Public Company
Accounting Oversight Board (United States), we
considered the Fund's internal control over financial
reporting, including controls over safeguarding
securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion on
the financial statements and to comply with the
requirements of Form N-CEN, but not for the purpose of
expressing an opinion on the effectiveness of the Fund's
internal control over financial reporting. Accordingly, we
express no such opinion.
Management of the Fund is responsible for establishing
and maintaining effective internal control over financial
reporting. In fulfilling this responsibility, estimates and
judgments by management are required to assess the
expected benefits and related costs of controls. A
company's internal control over financial reporting is a
process designed to provide reasonable assurance
regarding the reliability of financial reporting and the
preparation of financial statements for external purposes
in accordance with generally accepted accounting
principles. A company's internal control over financial
reporting includes those policies and procedures that (1)
pertain to the maintenance of records that, in reasonable
detail, accurately and fairly reflect the transactions and
dispositions of the assets of the company; (2) provide
reasonable assurance that transactions are recorded as
necessary to permit preparation of financial statements
in accordance with generally accepted accounting
principles, and that receipts and expenditures of the
company are being made only in accordance with
authorizations of management and directors of the Fund
and (3) provide reasonable assurance regarding
prevention or timely detection of unauthorized
acquisition, use, or disposition of the company's assets
that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect
misstatements. Also, projections of any evaluation of
effectiveness to future periods are subject to the risk that
controls may become inadequate because of changes in
conditions, or that the degree of compliance with policies
or procedures may deteriorate.
A deficiency in internal control over financial reporting
exists when the design or operation of a control does not
allow management or employees, in the normal course
of performing their assigned functions, to prevent or
detect misstatements on a timely basis. A material
weakness is a deficiency, or a combination of
deficiencies, in internal control over financial reporting,
such that there is a reasonable possibility that a material
misstatement of the Fund's annual or interim financial
statements will not be prevented or detected on a timely
basis.
Our consideration of the Fund's internal control over
financial reporting was for the limited purpose described
in the first paragraph and would not necessarily disclose
all deficiencies in internal control that might be material
weaknesses under standards established by the Public
Company Accounting Oversight Board (United States).
However, we noted no deficiencies in the Fund's internal
control over financial reporting and its operation,
including controls over safeguarding securities that we
consider to be a material weakness as defined above as
of October 31, 2018.
This report is intended solely for the information and use
of management and the Board of Trustees of Aberdeen
Global Dynamic Dividend Fund and the Securities and
Exchange Commission and is not intended to be and
should not be used by anyone other than these specified
parties.
/s/ KPMG LLP Philadelphia, Pennsylvania December 27, 2018 |
Information Classification: Limited Access
Information Classification: Limited Access