SECURITIES AND EXCHANGE COMMISSION

Investment Company Act Release No. 35053; 812-15509

CAZ Strategic Opportunities Fund and CAZ Investments Registered Adviser LLC

November 21, 2023

AGENCY: Securities and Exchange Commission (“Commission” or “SEC”).

ACTION: Notice.

Notice of an application for an order pursuant to section 6(c) of the Investment Company Act of 

1940 (the “Act”) for an exemption from sections 18(a)(2), 18(c), and 18(i) of the Act, pursuant to 

sections 6(c) and 23(c) of the Act for an exemption from rule 23c-3 under the Act, and pursuant 

to section 17(d) of the Act and rule 17d-1 thereunder.

Summary of Application: Applicants request an order to permit certain registered closed-end 

investment companies to issue multiple classes of shares and to impose early withdrawal charges 

and asset-based distribution and/or service fees.

Applicants: CAZ Strategic Opportunities Fund and CAZ Investments Registered Adviser LLC

Filing Date: The application was filed on September 29, 2023 and amended on November 15, 

2023.

Hearing or Notification of Hearing: An order granting the requested relief will be issued unless 

the Commission orders a hearing. Interested persons may request a hearing on any application 

by e-mailing the SEC’s Secretary at Secretarys-Office@sec.gov and serving the Applicants with 

a copy of the request by e-mail, if an e-mail address is listed for the relevant Applicant below, or 

personally or by mail, if a physical address is listed for the relevant Applicant below. Hearing 

requests should be received by the Commission by 5:30 p.m. on December 18, 2023, and should 

be accompanied by proof of service on the Applicants, in the form of an affidavit, or, for 
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lawyers, a certificate of service. Pursuant to rule 0-5 under the Act, hearing requests should state 

the nature of the writer’s interest, any facts bearing upon the desirability of a hearing on the 

matter, the reason for the request, and the issues contested. Persons who wish to be notified of a 

hearing may request notification by emailing the Commission’s Secretary. 

ADDRESSES: The Commission: Secretarys-Office@sec.gov. Applicants: Christopher Alan 

Zook, CAZ Strategic Opportunities Fund, caz@cazinvestments.com; with a copy to Thomas 

Friedmann, Dechert LLP, thomas.friedmann@dechert.com; Matthew Carter, Dechert LLP, 

matthew.carter@dechert.com; and Alexander Karampatsos, Dechert LLP, 

alexander.karampatsos@dechert.com. 

FOR FURTHER INFORMATION CONTACT: Trace W. Rakestraw, Senior Special Counsel, at 

(202) 551-6825 (Division of Investment Management, Chief Counsel’s Office).

SUPPLEMENTARY INFORMATION: For Applicants’ representations, legal analysis, and 

conditions, please refer to Applicants’ application, dated November 15, 2023, which may be 

obtained via the Commission’s website by searching for the file number at the top of this 

document, or for an Applicant using the Company name search field on the SEC’s EDGAR 

system. The SEC’s EDGAR system may be searched at 

https://www.sec.gov/edgar/searchedgar/legacy/companysearch.html. 
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You may also call the SEC’s Public Reference Room at (202) 551-8090.

For the Commission, by the Division of Investment Management, under delegated 

authority.

J. Matthew DeLesDernier,

Deputy Secretary.