ASA
Gold and Precious Metals Limited
Certification by the Chief Compliance Officer
SEC File No. 812-13877
In accordance with Condition 31 of the Notice of Application under section 7(d) of the Investment Company Act of 1940 dated May 22, 2013, for the order
granted by the Securities and Exchange Commission to permit ASA Gold and Precious Metals Limited (“ASA”) to make changes to its custodial arrangements without prior Commission approval, hold assets and conduct certain securities transactions in
specified foreign countries, as well as permit the Company and certain other persons to designate CT Corporation System in the US to accept service of process, I hereby certify pursuant to item G.1a.v. of Form N-CEN that the Company and its Board
have established procedures reasonably designed to achieve compliance with Conditions 22, 25 and 26 regarding the location of ASA’s assets.
By: /s/ Jack Huntington
Jack Huntington
Chief Compliance Officer
Three Canal Plaza, Suite 600
Portland, ME, U.S.A. 04101
ASA
Gold and Precious Metals Limited
SEC File No. 812-13877
Investment Company Act Release No. 30539
In response to Item G.1.a.v. of Form N-CEN, for information required to be filed pursuant to exemptive orders, please find the following:
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1.
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An updated list of the directors’ affiliations in accordance with condition #8 of the exemptive order, which states, in relevant part, “[The Company]
will furnish to the Commission revisions, if any, to the list of persons affiliated with [the Company] that previously was furnished to the Commission concurrently with the filing of periodic reports required to be filed under the Act.
Such revised lists will include persons affiliated with any future investment adviser or principal underwriter of [the Company].”
SEC File No. 812-13877; Investment Company Act Release No. 30539
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2.
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A certification from the Company’s Chief Compliance Officer in accordance with condition #31 of the Company’s exemptive order, which requires, among
other things, that the Company and its Board have established procedures reasonably designed to achieve compliance with conditions 22, 25, and 26 of the Company’s exemptive order regarding, among other things, the location of the
Company’s assets, the ability of the Company to make changes to its custodial arrangements without prior Commission approval, and the ability of the Company to hold assets and conduct certain securities transactions in specified foreign
countries.
SEC File No. 812-13877; Investment Company Act Release No. 30539
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Three Canal Plaza, Suite 600 Portland, ME, U.S.A. 04101
ASA
Gold and Precious Metals Limited
January 31, 2024
Certification by the Chief Compliance Officer
SEC File No. 812-13877
ASA Gold and Precious Metals
List of Affiliated Persons of Directors and Officers
As of January 31, 2024
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Officer or Director
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Affiliated Person
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Peter Maletis, President
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Merk Investments LLC
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Axel Merk, Chief Operating Officer
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Merk Investments LLC
Merk Global Opportunity Fund LP
Merk Capital Partners LP
Prelude Opportunity Fund LP
VanEck Merk Gold Trust
Sedlmayr Grund u Immobilien AG (Germany)
Merk Stagflation ETF (Cayman)
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Karen Shaw, Principal Financial Officer
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None
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Jack Huntington, Chief Compliance Officer
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None
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Zac Tackett, Corporate Secretary
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None
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Bruce Hansen, Director
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Energy Fuels Inc.
New Moly LLC
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| Mary Joan Hoene, Director (Chair) |
None |
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Willian Donovan, Director
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None
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By: /s/ Jack Huntington
Jack Huntington
Chief Compliance Officer
Three Canal Plaza, Suite 600
Portland, ME, U.S.A. 04101
ASA
Gold and Precious Metals Limited
Section 16(a) of the Securities Exchange Act of 1934 and Section 30(h) of the Investment Company Act of 1940 require the Company’s directors, officers
and persons who beneficially own more than 10 percent of the Company’s Common Shares to file reports of ownership of the Company’s Common Shares and changes in such ownership on Forms 3, 4, and 5 with the Commission. Such persons are required by SEC
regulations to furnish the Company with copies of all such filings. Based solely upon a review of the copies ofsuch forms furnished and except as noted below, the Companydoes not know of any director,officer or person who beneficially owns more than
10 percent of the Company’s Common Shares who,during the Company’s last fiscal year, failed to file on a timely basis the required reports.
Three Canal Plaza, Suite 600
Portland, ME, U.S.A. 04101
TAIT|WELLER
FOCUS, EXPERTISE, RESULTS
CERTIFIED PUBLIC ACCOUNTANTS
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
To the Shareholders and Board of Directors
ASA Gold and Precious Metals Limited
Portland, Maine
In planning and performing our audit of the financial statements of ASA Gold and Precious Metals Limited (the “Company”) as of and for the year
ended November 30, 2023, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered its internal control over financial reporting, including control activities for safeguarding securities, as a
basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the
Company’s internal control over financial reporting. Accordingly, we express no such opinion.
The management of the Company is responsible for establishing and maintaining effective internal control over financial
reporting. In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls. A company’s internal control over financial reporting is a process designed to
provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with accounting principles generally accepted in the United States of America. Such
internal control includes policies and procedures that provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a company’s assets that could have a material effect on the financial
statements.
Because of inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any
evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.
A control deficiency exists when the design or operation of a control does not allow management or employees, in the normal course of performing
their assigned functions, to prevent or detect misstatements on a timely basis. A significant deficiency is a control deficiency, or combination of control deficiencies, that adversely affects the company’s ability to initiate, authorize, record,
process or report financial data reliably in accordance with accounting principles generally accepted in the United States of America such that there is more than a remote likelihood that a misstatement of the company’s annual or interim financial
statements that is more than inconsequential will not be prevented or detected. A material weakness is a significant deficiency, or combination of significant deficiencies, that results in more than a remote likelihood that a material misstatement
of the annual or interim financial statements will not be prevented or detected.
Shareholders and Board of Directors
ASA Gold and Precious Metals Limited
Page Two
Our consideration of the Company’s internal control over financial reporting was for the limited purpose described in the first paragraph and would
not necessarily disclose all deficiencies in internal control that might be significant deficiencies or material weaknesses under standards established by the Public Company Accounting Oversight Board (United States). However, we noted no
deficiencies in the Company’s internal control over financial reporting and its operation, including controls for safeguarding securities, which we consider to be material weaknesses, as defined above, as of November 30, 2023.
This report is intended solely for the information and use of management, Shareholders and Board of Directors of the Company and the Securities and
Exchange Commission, and is not intended to be and should not be used by anyone other than these specified parties.
/s/ Tait, Weller & Baker LLP
TAIT, WELLER & BAKER LLP
Philadelphia, Pennsylvania
January 29, 2024