June 15, 2018

Sandra Hunter Berkheimer

Office of Real Estate and Commodities

Securities and Exchange Commission

Washington, D.C. 20549

Dear Ms. Berkheimer:

This is in response to your letter of June 14, 2018. We have copied below the comment from your June 14th letter, and provided the Fund’s response below it. Also enclosed are clean and blacklined versions of the Offering Circular reflecting the changes we have made in response to your letter, each of which is described below.

 

The revised Offering Circular (but not the blacklined version) has also been filed through EDGAR.

 

Your Question #1

 

 

1. We note your revisions in response to comment 2 of our prior letter. Please revise your disclosure to confirm whether the waiver of trial by jury provision applies to claims made under the federal securities laws. Please also confirm that Delaware law permits such a provision, or alternatively address any questions as to enforceability.

 

 

*      *      *

 

Thank you for your continued attention to this matter. Please let us know if you have further questions or need additional information.

 

	Very truly yours,
	Markley S. Roderick

Enclosures

cc:  Edward P. Lorin, CEO (sent via email with enclosures)