August 30, 2024
Filing Desk
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re:
Allspring Funds Trust – File Nos. 333-74295; 811-09253
Allspring Master Trust – File No. 811-09689
Allspring Variable Trust – File Nos. 333-74283; 811-09255
Allspring Income Opportunities Fund – File No. 811-21269
Allspring Multi-Sector Income Fund – File No. 811-21331
Allspring Utilities and High Income Fund – File No. 811-21507
Allspring Global Dividend Opportunity Fund – File No. 811-22005
Dear Sir or Madam:
Pursuant to Rule 17g-1(g)(1)(B) of the Investment Company Act of 1940, we are filing on behalf of Allspring Funds Trust, Allspring Master Trust, Allspring Variable Trust, Allspring Income Opportunities Fund, Allspring Multi-Sector Income Fund, Allspring Utilities and High Income Fund and Allspring Global Dividend Opportunity Fund (each, a “Trust” and together, the “Trusts”): (i) a copy of the joint insured fidelity bond (including seven excess bonds) to which each Trust is a named insured; (ii) a copy of the resolutions of a majority of the board of trustees who are not “interested persons” of each Trust approving the amount, type, form and coverage of the bond and the portion of the premium to be paid by each Trust; and (iii) a copy of the agreement between each Trust and the other named insureds entered into pursuant to paragraph (f) of the rule.
In addition, each Trust states that the following represents the amount of the single insured bond which it would have had to provide and maintain had it not been named as an insured under the joint insured bond:
Allspring Funds Trust - $2,500,000
Allspring Master Trust - $2,500,000
Allspring Variable Trust - $1,000,000
Allspring Income Opportunities Fund - $900,000
Allspring Multi-Sector Income Fund - $750,000
Allspring Utilities and High Income Fund - $525,000
Allspring Global Dividend Opportunity Fund - $750,000
Pursuant to the rule, the above amount is based on gross assets at the end of the most recent fiscal quarter prior to the date of determination. The premiums for the period commencing September 1, 2024 to September 1, 2025 have been paid.
Sincerely,
Kate Johnson
Assistant Secretary
Resolutions of the majority of the Board of Trustees (“Board”)
who are not “interested persons” of the registered investment company
August 12-14, 2024 Board Meetings
FUNDS TRUST
MASTER TRUST
VARIABLE TRUST
GLOBAL DIVIDEND OPPORTUNITY FUND
INCOME OPPORTUNITIES FUND
MULTI-SECTOR INCOME FUND
UTILITIES AND HIGH INCOME FUND
RESOLVED, that the Board, including a majority of the Independent Trustees, hereby determines, with due consideration to (i) the value of the aggregate assets of the Funds to which any person may have access, (ii) the terms of the arrangements made for the custody and safekeeping of such assets, (iii) the nature of securities in the Funds, and (iv) the amount of the bond and the premium of such bond, that such bond in the aggregate amount presented at this meeting of $135 million is in reasonable form and amount; and
FURTHER RESOLVED, that the Officers be, and each hereby is, authorized and directed to determine an appropriate increase in the fidelity bond coverage, based on assets under management, during the policy, if necessary; and
FURTHER RESOLVED, that the Board, including a majority of the Independent Trustees, after taking all relevant factors into consideration, including, but not limited to, (i) the number of other parties, (ii) the amount of the joint insured bond, (iii) the amount of the premium for such bond, (iv) the ratable allocation of the premium among all parties as insured, and (v) the extent to which the share of the premium allocated to each Fund is less than the premium it would have had to pay if it had provided and maintained a single insured bond, hereby approves the portion of the premium to be paid by each Fund, which is a pro rata portion equal to the ratio of each Fund’s net assets to the aggregate net assets of all the parties; and
FURTHER RESOLVED, that the Officers be, and each hereby is, authorized and directed to negotiate the final terms of the joint fidelity bond, and to execute and deliver on behalf of each Trust any and all documents related thereto, in such form and with such changes (including final premium amount) as such Officer, in consultation with counsel, deems appropriate or advisable; and
FURTHER RESOLVED, that the Joint Fidelity Bond Allocation Agreement among Funds Trust, Master Trust, Variable Trust, Global Dividend Opportunity Fund, Income Opportunities Fund, Multi-Sector Income Fund and Utilities and High Income Fund, which provides for an equitable and proportionate share of any recovery under the joint fidelity bond, be, and it hereby is, reapproved; and
FURTHER RESOLVED, that the Officers be, and each here by is, authorized, empowered and directed to make all filings with the SEC, and to give all notices, required by paragraph (g) of Rule 17g-1 under the 1940 Act.
JOINT FIDELITY BOND
ALLOCATION AGREEMENT
Amended and Restated
December 16, 2021
WHEREAS, Allspring Funds Trust (“Funds Trust”), Allspring Master Trust (“Master Trust”) and Allspring Variable Trust (“Variable Trust”) are open-end management investment companies registered as such under the 1940 Act, consisting of investment portfolios as detailed in Appendix A; and
WHEREAS, Allspring Global Dividend Opportunity Fund, Allspring Income Opportunities Fund, Allspring Multi-Sector Income Fund and Allspring Utilities and High Income Fund (the “Closed-End Funds”) are closed-end management investment companies registered as such under the 1940 Act; and
WHEREAS, Funds Trust, Master Trust, Variable Trust and the Closed-End Funds are required to provide and maintain a fidelity bond pursuant to Rule 17g-1 under the 1940 Act; and
WHEREAS, Rule 17g-1(b) provides that the fidelity bond may be in the form of a joint insured bond covering Funds Trust, Master Trust, Variable Trust; and
WHEREAS, the Trustees of Funds Trust, Master Trust and Variable Trust and the Closed-End Funds, including a majority of such Trustees who are not “interested persons” (as that term is defined in the 1940 Act) have made the required determinations required by that Rule, including those provisions specifically applicable to a joint insured bond;
NOW, THEREFORE, Funds Trust, Master Trust, Variable Trust and the Closed-End Funds hereby agree as follows:
1.
Each of Funds Trust, Master Trust, Variable Trust and the Closed-End Funds will pay a portion of the premiums for the joint insured fidelity bond which is allocated pro rata according to the percentage each of their net assets bear to the aggregate net assets of all the insured parties.
2.
In the event recovery is received under the joint insured bond as a result of a loss sustained by two or more of the insured parties, each party shall receive an equitable and proportionate share of the recovery, but at least equal to the amount which such party would have received had it provided and maintained a single insured bond with the minimum coverage required by paragraph (d)(1) of Rule 17g-1 under the 1940 Act.
This agreement may be executed simultaneously in two or more counterparts, each of which shall be deemed an original, but all of which taken together shall constitute one and the same instrument.
ALLSPRING FUNDS TRUST
By:
___________________________
Matthew Prasse
Secretary
ALLSPRING MASTER TRUST
By:
___________________________
Matthew Prasse
Secretary
ALLSPRING VARIABLE TRUST
By:
___________________________
Matthew Prasse
Secretary
ALLSPRING GLOBAL DIVIDEND OPPORTUNITY
FUND
By:
___________________________
Matthew Prasse
Secretary
ALLSPRING INCOME OPPORTUNITIES FUND
By:
___________________________
Matthew Prasse
Secretary
ALLSPRING MULTI-SECTOR INCOME FUND
By:
___________________________
Matthew Prasse
Secretary
ALLSPRING UTILITIES AND HIGH INCOME FUND
By:
___________________________
Matthew Prasse
Secretary
Appendix A
JOINT FIDELITY BOND
ALLOCATION AGREEMENT
ALLOCATION AGREEMENT
Allspring Funds Trust
100% Treasury Money Market Fund
Absolute Return Fund
Adjustable Rate Government Fund
Alternative Risk Premia Fund
Asset Allocation Fund
California Limited-Term Tax-Free Fund
California Tax-Free Fund
Common Stock Fund
Conservative Income Fund
Core Bond Fund
Core Plus Bond Fund
Disciplined Small Cap Fund
Disciplined U.S. Core Fund
Discovery All Cap Growth Fund1
Discovery Innovation Fund2
Discovery Large Cap Growth Fund3
Discovery Mid Cap Growth Fund4
Discovery Small Cap Growth Fund
Discovery SMID Cap Growth Fund5
Diversified Capital Builder Fund
Diversified Income Builder Fund
Emerging Growth Fund
Emerging Markets Equity Fund
Emerging Markets Equity Income Fund
Global Investment Grade Credit Fund
Global Long/Short Equity Fund
Government Money Market Fund
Government Securities Fund
Growth Fund
Heritage Money Market Fund6
1
On May 29, 2024, the Board of Trustees of Allspring Funds Trust approved the reorganization of the Allspring Discovery All Cap Growth Fund into the Allspring Growth Fund effective on or about July 26, 2024.
2
On May 29, 2024, the Board of Trustees of Allspring Funds Trust approved the name change of Allspring Discovery Innovation Fund to Allspring Innovation Fund effective on or about August 9, 2024.
3
On May 29, 2024, the Board of Trustees of Allspring Funds Trust approved the reorganization of the Allspring Discovery Large Cap Growth Fund into the Allspring Large Cap Growth Fund effective on or about July 26, 2024.
4
On May 29, 2024, the Board of Trustees of Allspring Funds Trust approved the name change of Allspring Discovery Mid Cap Growth Fund to Allspring Mid Cap Growth Fund effective on or about August 9, 2024.
5
On May 29, 2024, the Board of Trustees of Allspring Funds Trust approved the name change of Allspring Discovery SMID Cap Growth Fund to Allspring SMID Cap Growth Fund effective on or about August 9, 2024.
6
On May 29, 2024, the Board of Trustees of Allspring Funds Trust approved the reorganization of the Allspring Heritage Money Market Fund into the Allspring Government Money Market Fund effective on or about August 16, 2024.
High Yield Bond Fund
High Yield Municipal Bond Fund
Income Plus Fund
Index Asset Allocation Fund
Index Fund
Intermediate Tax/AMT-Free Fund
International Equity Fund
Large Cap Core Fund
Large Cap Growth Fund
Large Cap Value Fund
Large Company Value Fund
Managed Account CoreBuilder Shares – Series CP
Managed Account CoreBuilder Shares – Series EM
Managed Account CoreBuilder Shares – Series EPI
Managed Account CoreBuilder Shares - Series M
Minnesota Tax-Free Fund
Money Market Fund
Municipal Bond Fund
Municipal Sustainability Fund
National Tax-Free Money Market Fund
Opportunity Fund
Pennsylvania Tax-Free Fund
Precious Metals Fund
Premier Large Company Growth Fund
Real Return Fund
Short Duration Government Bond Fund
Short-Term Bond Plus Fund
Short-Term High Income Fund
Short-Term Municipal Bond Fund
Small Company Growth Fund
Small Company Value Fund
Special Global Small Cap Fund
Special International Small Cap Fund
Special Large Cap Value Fund
Special Mid Cap Value Fund
Special Small Cap Value Fund
Spectrum Aggressive Growth Fund
Spectrum Conservative Growth Fund
Spectrum Growth Fund
Spectrum Income Allocation Fund
Spectrum Moderate Growth Fund
Strategic Municipal Bond Fund
Treasury Plus Money Market Fund
Ultra Short-Term Income Fund
Ultra Short-Term Municipal Income Fund
U.S. Long/Short Equity Fund7
Utility & Telecommunications Fund
Wisconsin Tax-Free Fund
Allspring Master Trust
Core Bond Portfolio
Disciplined International Developed Markets Portfolio
Disciplined Large Cap Portfolio
Diversified Large Cap Growth Portfolio
Emerging Growth Portfolio8
Large Cap Value Portfolio
Large Company Value Portfolio
Allspring Macro Strategies Portfolio
Managed Fixed Income Portfolio
Real Return Portfolio
Small Company Growth Portfolio
Small Company Value Portfolio
Allspring Variable Trust
VT Discovery All Cap Growth Fund
VT Discovery SMID Cap Growth Fund
VT Index Asset Allocation Fund
VT Opportunity Fund
VT Small Cap Growth Fund
Allspring Global Dividend Opportunities Fund
Allspring Income Opportunities Fund
Allspring Multi-Sector Income Fund
Allspring Utilities and High Income Fund
Appendix A Amended: May 29, 2024
7
On May 29, 2024, the Board of Trustees of Allspring Funds Trust approved the liquidation and termination of the Allspring U.S. Long/Short Equity Fund effective on or about July 26, 2024.
8
On May 29, 2024, the Board of Trustees of Allspring Master Trust approved the liquidation and termination of the Allspring Emerging Growth Portfolio effective on or about September 13, 2024.