Fair Value & Investments

Company response: The Company acknowledges the Staff’s comment and confirms that in the future it will revise the footnote to the Schedule of Investments in its Quarterly Reports on Form 10-Q and its next Annual Report on Form 10-K to reflect that the value of Level 3 holdings was determined using significant unobservable inputs as required by Article 12-12, footnote 9 of Regulation S-X consistent with the following: Unless otherwise noted, security is a Level 3 holding. As of December 31, 2025, the aggregate value of Level 3 securities held by the Company was $2,151,743. The value of each investment was determined using unobservable inputs. See Note 5 – Fair Value. response letter →

Company response: In our consideration of providing financial statements or summarized financial information for our equity method investments in our unconsolidated real estate ventures and Managed REITs, we evaluated and performed the requisite calculations pursuant to Rule 3-09 of Regulation S-X (“Rule 3-09”) and Rule 4-08(g) of Regulation S-X (“Rule 4-08(g)”). With respect to the Investment Test and Income Test required by Rule 3-09, we determined that none of our equity method investments were in excess of the 20% thresholds. Therefore, separate financial statements of the equity method investees were not required. Similarly, with respect to the Investment Test, Asset Test and Income Test, in accordance… response letter →

Company response: We acknowledge the Staff’s comment. Consistent with our policy, we elected to bypass the qualitative assessment and performed a quantitative goodwill impairment analysis for each of the reporting units as of December 27, 2025. ASC 350-20-35-3B provides the unconditional option to bypass the qualitative assessment and proceed directly to the quantitative goodwill impairment test. We elected this approach for all reporting units due to the length of time that had elapsed since our previous quantitative assessment. response letter →

Company response: The Company acknowledges the Staff’s comment. The Company’s equity investment, without a readily determinable fair value, is the less-than-1% ownership interest in New Markets (BVI) Limited (Microconnect), which is accounted for in accordance with ASC 321-10-35-2, 35-3, and 35-4, instead of the “other than temporary” method mentioned in Note 2(n) of the consolidated financial statements of the Company for the years ended March 31, 2025 and 2024. Specifically, the Company performed a qualitative assessment for impairment indicators according to ASC 321-10-35-3 as of March 31, 2025 and 2024, respectively. The Company identified impairment indicators, including significant operating losses and… response letter →

Company response: 1. The Company respectfully acknowledges the Staff’s comment and undertakes to revise our future filings, beginning with its Annual Report on Form 10-K for the year ending March 31, 2026, to enhance and expand its accounting policy disclosures related to goodwill and indefinite-lived intangible asset impairment in Note 2 to its Consolidated Financial Statements and within the Critical Accounting Estimates discussion within Management’s Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”). For example, in any period that goodwill is impaired and considered a non-recurring fair value measurement, the Company will include the applicable ASC 820 disclosures, such as… response letter →

Company response: Refer to Item 303(b)(3) of Regulation S-K and Section V of SEC Release No. 33-8350 for guidance. Company Response: In future filings, we will expand our critical accounting estimates disclosure to address all reporting units. We have included an example, italicized below, of what we would expect to disclose in a future filing assuming the facts and circumstances at September 30, 2025 and starting at the paragraph on page 51 beginning with "In fiscal 2025, the Company recorded a goodwill impairment on the Mechanical reporting unit of $18.9 million. . ." In fiscal 2025, the Company recorded a goodwill impairment on the Mechanical reporting unit of $18.9 million as a result of its annual… response letter →

Company response: to comment one. Please further revise your future filings as applicable to highlight that the change in fair value of contingent consideration of $15.0 million recognized during the three months ended August 31, 2025, resulted in net income for the period then ended, when we note you historically report a net loss. We appreciate the Staff’s comment and respectfully submit that we will revise our future filings pursuant to your comment above. response letter →

Company response: Refer to Item 303(b)(3) of Regulation S-K and Section V of SEC Release No. 33-8350 for guidance . Company Response In future filings, to the extent applicable, we will include as part of our critical accounting estimate disclosures the fact that no reporting units are at risk of failing the impairment test as they have a fair value that is substantially in excess of carrying value. Our proposed revised wording for this critical accounting estimate is below (changes underlined for emphasis). Proposed wording in future Form 10-K filings: Goodwill and Other Long-Lived Assets Our Management annually reviews goodwill and other long-lived assets for impairment or whenever events or changes in… response letter →

Company response: to the Staff’s comment, the Company respectfully submits that we will revise our future filings, as necessary, to describe the events that transpired during the three months ended August 31, 2025 that resulted in our determination that the $15.0 million payout was no longer likely to occur at all. response letter →

Company response: We acknowledge the Staff’s comment. In response thereto, we advise the Staff that in our presentation in future filings, commencing with the next 10-K filing, we will disclose if the fair value of a reporting unit substantially exceeds carrying value and is not at risk of failing, or if the fair value of a reporting unit does not substantially exceed the carrying value of the reporting unit, we will include the following disclosures: • the percentage by which fair value exceeded carrying value at the date of the most recent test; • a more detailed description of the methods and key assumptions used and how the key assumptions were determined; • a discussion of the degree of uncertainty… response letter →

Company response: , please confirm if cross-trades were executed in any of these securities during the relevant period pursuant to Rule 17a-7 of the Investment Company Act of 1940, as amended. Response: The Fund’s cash equivalents as of September 30, 2025 consisted of an investment in a single money market fund. In future filings, the Fund will identify the active markets used as a basis for determining that its cash equivalents are categorized as Level 1. The Fund, as well as other funds that are managed by an affiliate of the Fund’s investment adviser, actively transact in these money market funds on a daily basis. The Fund does not engage in cross-trades pursuant to Rule 17a-7 of the Investment Company… response letter →

Company response: The Fund respectfully submits that it will confirm the usage of all footnotes in the Level 3 investments table in its future filings. response letter →

Company response: , please confirm if cross-trades were executed in any of these securities during the relevant period pursuant to Rule 17a-7 of the Investment Company Act of 1940, as amended. Austin Bay Area Beijing Boston Brussels Chicago Dallas Frankfurt Hong Kong Houston London Los Angeles Miami Munich New York Paris Philadelphia Riyadh Salt Lake City Shanghai United States Securities and Exchange Commission Response: The Fund’s cash equivalents as of September 30, 2025 consisted of investments in two money market funds. In future filings, the Fund will identify the active markets used as a basis for determining that its cash equivalents are categorized as Level 1. The Fund, as well as other funds that… response letter →

Company response: Refer to ASC 230-10-45-21D. Response: The Company respectfully acknowledges the Staff’s comment. The Company has elected and will disclose in its upcoming Form 10-K for the year ending February 28, 2026 and future filings, to follow the cumulative earnings approach when determining the classification of distributions received from equity method investees, in accordance with ASC 230-10-45-21D. In future filings, beginning with the Company’s Form 10-K for the year ending February 28, 2026, we will update our accounting policy to include information substantially similar to the following: Investment in Unconsolidated Joint Venture We account for the investment in our joint venture under the… response letter →

Company response: As described in Critical Accounting Policies in the Company’s Form 10-K for the fiscal year ended December 31, 2024, the Company has identified Global Ceramic, Flooring North America (“Flooring NA”) and Flooring Rest of the World (“Flooring ROW”) as its reporting units for the purposes of allocating goodwill as well as assessing impairments. As of the Company’s 2024 annual goodwill impairment testing date, which was the first day of the fourth quarter of 2024 (the “2024 Annual Impairment Test Date”), the Company completed quantitative goodwill impairment tests (the “Annual Impairment Tests”) and determined that the estimated fair values of its reporting units with goodwill exceeded their… response letter →

Company response: The Fund hereby confirms that the par value approximates the fair value of the holdings. response letter →

Company response: The Fund respectfully confirms that a full assessment under ASC 820 was applied to its Level 3 Investments. The Fund clarifies that its Level 3 investments—the Capodagli NJ TOD portfolio mezzanine loan acquired in July 2024 and the Pearland preferred equity acquired in October 2023—are fair valued at the original par value. These prices represent the highest weighting and the most recent observable market transactions, with no material changes in operations, revenue, or capital markets, and no other relevant factors warranting adjustment as of December 31, 2024. Additionally, based on our standard quarterly analysis, we concluded that these investments do not require adjustment to fair… response letter →