Delaware Ivy High Income Opportunities Fund (IVH) CORRESPCorrespondence with SEC

Comment: Please confirm EDGAR has been updated to reflect Fund name changes and share classes that are no longer active.

Response: The Registrants are in the process of updating EDGAR to reflect Fund name changes and inactive share classes, as applicable, for the Registrants listed on Appendix A.

Comment: The below listed Funds reported high portfolio turnover in their respective financial highlights. Please explain if active and frequent trading is part of the Fund’s principal investment strategy, and if yes, why an applicable risk is not included as a principal risk in the summary prospectus.

Response: None of the Funds uses active and frequent trading as a principal investment strategy.  The higher one-year portfolio turnover rates were due to changes in investment strategies and portfolio managers in November 2021 for the Delaware Ivy Natural Resources Fund and Delaware Global Value

Comment: The audit opinions for the Delaware Healthcare Fund and the Delaware Small Cap Growth Fund are each dated May 31, 2022 which is more than 60 days after the Funds’ March 31 fiscal year ends. The Staff notes that Rule 30e-1(c) under the Investment Company Act of 1940, as amended (“1940 Act”), states that when transmitting reports to shareholders, “[e]ach report shall be transmitted within 60 days after the close of the period for which such report is being made.” (Emphasis added.)

Response: The Registrants will review their controls and will make changes to ensure that shareholder reports are transmitted within 60 days of their fiscal year ends, which may require transmission earlier than the 60^th day to be in compliance with Rule 30e-1(c) if the 60^th days falls on a weekend or holiday.

Comment: The report of independent registered public accounting firm contained in the September 2021 annual shareholder report for the Delaware Ivy High Income Opportunities Fund notes “our procedures included confirmation of securities owned as of June 30, 2021.” However, the Fund’s fiscal year end is September 30. Please correct the opinion and file an amended N-CSR as soon as possible.

Response: The requested change will be made and an amended N-CSR will be filed reflecting the correction of the error.  The Registrant anticipates filing an amended N-CSR by February 28, 2023.

Comment: The report of independent registered public accounting firm contained in the annual shareholder report for the Ivy Funds’ fiscal year end March 31, 2022 misstated the money market fund name.  Please correct the report and refile.

Response:  The requested change will be made. The Registrant anticipates filing an amended N-CSR to reflect the revision by February 28, 2023.

Comment: For the Funds listed as 1-27, 75-81 and 86-88 on Appendix A, Item 2 on their Forms N-CSR notes that the applicable Registrant has adopted a code of ethics that applies to its principal executive officer, principal financial offer, principal accounting officer or controller, or persons performing similar functions, a copy of which has been posted on the Funds’ website.  Supplementally, please explain where the business code of ethics is located, including a web link.

Response: The business code of ethics can be accessed by clicking on Additional Information/Business ethics at the bottom of the mutual funds’ home page on the delawarefunds.com website.  The direct link is: https://www.delawarefunds.com/about/business-ethics.

Comment: During the previous Sarbanes-Oxley review of the Ivy Funds, the staff requested confirmation that the Delaware Ivy Asset Strategy Fund apply Financial Accounting Standards Board Accounting Standards Codification 850 (“FASB 850”), and that the Fund file Form 40-33, with respect to a stockholders’ derivative action. The correspondence confirmed that the Fund complied with FASB 850, but acknowledged that it had not filed the Form 40-33 and undertook to do so as soon as possible. Please provide the link to the firm filing in EDGAR and the specific date the form was filed.

Response: The Registrant did not file Form 40-33, which request was made prior to the Fund becoming part of the Delaware Funds by Macquarie complex.  The Registrant filed the Form on February 1, 2023.

Comment: Please explain how the Macquarie Emerging Markets Portfolio II meets diversification requirements under the 1940 Act considering that individual investments representing more than 5% of its total assets are greater than 25% of its total assets.

Response:  Fund management has reviewed the schedule of investments in the Fund’s October 2021 annual report.  At the time of the report, certain individual investments exceeded 5% of the Fund’s total assets due to their appreciation in value after purchase by the Fund. Accordingly, the Registrant believes that the Fund’s portfolio was diversified at the end of the reporting period for the October 2021 annual report.

Comment: The annual report for the Funds listed below identify them as non-diversified within the meaning of the 1940 Act; however, each Fund appears to be operating as a diversified fund. If a Fund has been operating as a diversified fund for more than three years, please confirm that such Fund will solicit shareholder approval prior to resuming operations as a non-diversified Fund.

Response: The Registrants’ investment risk group has confirmed that the Delaware Ivy VIP Science and Technology, Delaware Ivy Emerging Markets Local Currency Debt Fund and Delaware Ivy LaSalle Global Real Estate Fund have operated as non-diversified for all, or parts, of the past three years.  The Registrant confirms that if a previously non-diversified Fund has been operating continuously as a diversified Fund for three or more years, shareholder approval will be sought before converting back to a non-diversified Fund.

Comment: The Statement of Assets and Liabilities in the 2021 annual report for the Delaware Ivy Accumulative Fund disclosed securities lending activities. However, the Fund’s Form N-CEN filed on September 3, 2021 did not disclose that the Fund lent securities. Please explain this discrepancy.

Response: Management Investment Record: 2 for Delaware Ivy Accumulative Fund shows that it responded affirmatively to Item C.6.b, indicating that the Fund had lent portfolio securities during the reporting period.  Therefore, the Registrant does not believe there is a discrepancy between the Fund’s annual report and Form N-CEN disclosures.

Comment: The Notes to the Financial Statements in the 2021 annual report for the Delaware Ivy Wilshire Global Allocation Fund disclosed reimbursement for costs of defense of a derivatives action.  The staff notes that on the Form N-CEN for the period ended June 30, 2021, which was filed on September 3, 2021, the Registrant responded “no” to Item B.11.b regarding legal proceedings. Please explain this discrepancy.

Response: Item B.11.b asks if any proceeding previously reported has been terminated.  Because the derivative action described in the Fund’s Notes to Financial Statements was not material it had not been previously reported on Form N-CEN, Item B.11.a.  Accordingly, the Registrant responded in the negative to Item B.11.b. The reason that the reimbursement payment was reported in the Notes was because the payment flowed through to the Fund’s financial statements and an explanation was required by GAAP, not because the litigation was material.

Comment: In their annual report, the Funds listed below noted that their Board of Trustees had approved the Funds’ liquidation. Please confirm whether the liquidations have occurred and provide specifics relating to said liquidations. If not, please provide the estimated date of liquidation. If there are other funds to be liquidated, please disclose same.

Response: The Registrants confirm that the Funds have liquidated following Board approval, notice to shareholders, the orderly liquidation of the Funds’ portfolios and the pro rata distribution of the proceeds to shareholders.  In addition, the Macquarie Emerging Markets Portfolio II was liquidated effective June 30, 2022 following the same process as with the above listed Funds.  Finally, the Board has approved the liquidation of the Macquarie Emerging Markets Portfolio and the Macquarie Labor Select International Equity Portfolio.  These Portfolios will also follow the same liquidation process as noted for the above listed Funds. The Macquarie Labor Select International Equity Portfolio was liquidated on December 8, 2022 and the Registrant anticipates completing the liquidation of the Macquarie Emerging Markets Portfolio by the end of the first quarter of 2023.

Comment: The staff noted that the Form N-CEN filings for the Registrants listed below indicated that there was a change in accountants.  The staff, however, did not see an “agreement letter” from the Funds’ predecessor auditor attached as an exhibit to Item 13(a)(4) in Form N-CSR. Please refer to Dear CFO letter 1998-04 for the disclosure requirements regarding a change in auditor and amend the filings accordingly.

Response: The foregoing Registrants will amend their applicable Form N-CSR filings to include the predecessor’s auditor agreement letter as an exhibit. The Registrants anticipate filing amended N-CSRs by February 28, 2023.

Comment: A review of the Funds’ applicable annual reports on Form N-CSR showed that they had not included the required disclosure concerning the operation of their liquidity risk management program. This comment applies to all of the Funds listed on Appendix A except for the following:  Delaware Ivy Accumulative Fund, Delaware Ivy Wilshire Global Allocation Fund, Macquarie Emerging Markets Portfolio, Macquarie Emerging Markets Portfolio II Fund, Macquarie Labor Select International Equity Portfolio Fund, Delaware Global Listed Real Assets Fund, Macquarie High Yield Bond Portfolio Fund, Macquarie Core Plus Bond Portfolio Fund, and Macquarie Large Cap Value Portfolio Fund. Please explain why the disclosure was not included.

Response:  The liquidity risk management program statement is included under the “Other information” section in the Ivy Variable Insurance Portfolios’ semi-annual report for the period ended June 30, 2021;  in the Healthcare, Smid Cap Core and Small Cap Growth Funds’ semi-annual reports for the period ended September 30, 2021; in the Delaware Limited-Term Diversified Income Fund’s semi-annual report dated June 30, 2021; and in the Delaware Tax-Free New Jersey and Delaware Tax-Free Oregon Funds’ semi-annual report dated June 30, 2021.  In addition, for 2022, the liquidity risk management disclosure for the Ivy Funds was moved from the annual/semi-annual reports for the period ended March 31 to the annual/semi-annual reports for the period ended September 30 due to the timing of the reporting to the Board on the operation of the program.  Finally, the Delaware Ivy High Income Opportunities Fund and Macquarie Global Infrastructure Total Return Fund, Inc. do not include liquidity risk management program disclosure because both Funds are closed-end funds and are not required to comply with Rule 22e-4.

Comment: Explain supplementally whether the Registrants’ Board of Trustees/Directors has received an annual written report from the Registrants’ Liquidity Risk Management Program administrator that addresses the operation of the program and assesses its adequacy and effectiveness of implementation, and any material changes to the program as required by Rule 22e-4(b)(2)(iii) under the 1940 Act. This applies to all of the funds except the following: Delaware Ivy Accumulative Fund, Delaware Ivy Wilshire Global Allocation Fund, Macquarie Emerging Markets Portfolio, Macquarie Emerging Markets Portfolio II Fund, Macquarie Labor Select International Equity Portfolio Fund, Delaware Global Listed Real Assets Fund, Macquarie High Yield Bond Portfolio Fund, Macquarie Core Plus Bond Portfolio Fund, and Macquarie Large Cap Value Portfolio Fund.

Response: The Registrants so confirm.

Comment: Explain why the performance numbers for the “Fund at net asset value” and “Fund at market price” as disclosed in the manager’s discussion of Fund performance for the Delaware Ivy High Income Opportunities Fund do not agree with the numbers in the Fund’s portfolio highlights and financial highlights sections of its annual report.

Response: The performance numbers shown in the manager’s discussion of Fund performance and its portfolio highlights and financial highlights should be the same; however, the incorrect performance numbers were the ones included in the manager’s discussion of Fund performance, not in the portfolio highlights or financial highlights.  The Registrant will ensure that the performance numbers used in future reports are used consistently throughout the reports.

Comment: The “Other liabilities” line item in the Statement of Assets and Liabilities appears to be significant. Please confirm that any significant liabilities have been disclosed and broken out as required by Regulation S-X Rule 6-01.  In the future, ensure that significant liabilities are separately broken out in the Statement of Assets of Liabilities. Examples of Funds with significant “Other liabilities” (i.e., in excess of 40% of “Total liabilities”) include the following but confirm for all Funds:

Response: The Registrant confirms that there were not any significant individual liabilities that should have been broken out on as an individual line-item under the “Liabilities” section of each Fund’s Statement of Assets and Liabilities consistent with the requirements of Regulation S-X.  The Registrant further confirms that any significant individual liabilities will be broken out as a separate line-item in future shareholder reports.

Comment: The Statement of Assets and Liabilities in several Funds’ annual reports noted the payment of legal fees to affiliates. Please explain what these fees represent and explain the differences between payments to affiliates and non-affiliates.  Examples of Funds that made these payments include:

Response: The advisory agreements between the Funds and Delaware Management Company (“DMC”) include a provision that allocates to the Funds the cost of certain expenses associated with the provision of legal services to the Funds by DMC personnel.  These are separate and distinct from the expenses associated with legal services provided by external counsel.

Comment: According to the statement of changes in net assets, Delaware Limited-Term Diversified Income Fund had a return of capital distribution. Please confirm supplementally that there is no reference to yield or dividends when describing distributions that may contain return of capital in marketing, financial statement disclosures, or website disclosures.

Response: The Registrant confirms that disclosures concerning Fund distributions distinguish between distributable earnings and returns of capital.