SCHEDULE 13D/A
DATE OF EVENT WHICH REQUIRES FILING OF THIS STATEMENT
2/23/15
1. NAME OF REPORTING PERSON
Bulldog Investors, LLC
2. CHECK THE BOX IF MEMBER OF A GROUP a[ ]
b[]
3. SEC USE ONLY
4. SOURCE OF FUNDS
WC
5. CHECK BOX IF DISCLOSURE OF LEGAL PROCEEDINGS IS REQUIRED
PURSUANT TO ITEMS 2(d) AND 2(e) []
6. CITIZENSHIP OR PLACE OF ORGANIZATION
DE
___________________________________________________________
7. SOLE VOTING POWER
512,720
8. SHARED VOTING POWER
477,417
9. SOLE DISPOSITIVE POWER
512,720
_______________________________________________________
10. SHARED DISPOSITIVE POWER
477,417
11. AGGREGATE AMOUNT OWNED BY EACH REPORTING PERSON
990,137 (Footnote 1)
12. CHECK IF THE AGGREGATE AMOUNT EXCLUDES CERTAIN SHARES
[]
___________________________________________________________
13. PERCENT OF CLASS REPRESENTED BY ROW 11
8.65%
14. TYPE OF REPORTING PERSON
IA
___________________________________________________________
1. NAME OF REPORTING PERSON
Phillip Goldstein
2. CHECK THE BOX IF MEMBER OF A GROUP a[ ]
b[]
3. SEC USE ONLY
4. SOURCE OF FUNDS
WC
5. CHECK BOX IF DISCLOSURE OF LEGAL PROCEEDINGS IS REQUIRED
PURSUANT TO ITEMS 2(d) AND 2(e) []
6. CITIZENSHIP OR PLACE OF ORGANIZATION
USA
___________________________________________________________
7. SOLE VOTING POWER
512,720
8. SHARED VOTING POWER
477,417
9. SOLE DISPOSITIVE POWER
512,720
_______________________________________________________
10. SHARED DISPOSITIVE POWER
477,417
11. AGGREGATE AMOUNT OWNED BY EACH REPORTING PERSON
990,137 (Footnote 1)
12. CHECK IF THE AGGREGATE AMOUNT EXCLUDES CERTAIN SHARES
[]
___________________________________________________________
13. PERCENT OF CLASS REPRESENTED BY ROW 11
8.65%
14. TYPE OF REPORTING PERSON
IN
___________________________________________________________
1. NAME OF REPORTING PERSON
Andrew Dakos
2. CHECK THE BOX IF MEMBER OF A GROUP a[ ]
b[]
3. SEC USE ONLY
4. SOURCE OF FUNDS
WC
5. CHECK BOX IF DISCLOSURE OF LEGAL PROCEEDINGS IS REQUIRED
PURSUANT TO ITEMS 2(d) AND 2(e) []
6. CITIZENSHIP OR PLACE OF ORGANIZATION
USA
___________________________________________________________
7. SOLE VOTING POWER
512,720
8. SHARED VOTING POWER
477,417
9. SOLE DISPOSITIVE POWER
512,720
_______________________________________________________
10. SHARED DISPOSITIVE POWER
477,417
11. AGGREGATE AMOUNT OWNED BY EACH REPORTING PERSON
990,137 (Footnote 1)
12. CHECK IF THE AGGREGATE AMOUNT EXCLUDES CERTAIN SHARES
[]
___________________________________________________________
13. PERCENT OF CLASS REPRESENTED BY ROW 11
8.65%
14. TYPE OF REPORTING PERSON
IN
___________________________________________________________
1. NAME OF REPORTING PERSON
Steven Samuels
2. CHECK THE BOX IF MEMBER OF A GROUP a[ ]
b[]
3. SEC USE ONLY
4. SOURCE OF FUNDS
WC
5. CHECK BOX IF DISCLOSURE OF LEGAL PROCEEDINGS IS REQUIRED
PURSUANT TO ITEMS 2(d) AND 2(e) []
6. CITIZENSHIP OR PLACE OF ORGANIZATION
USA
___________________________________________________________
7. SOLE VOTING POWER
512,720
8. SHARED VOTING POWER
477,417
9. SOLE DISPOSITIVE POWER
512,720
_______________________________________________________
10. SHARED DISPOSITIVE POWER
477,417
11. AGGREGATE AMOUNT OWNED BY EACH REPORTING PERSON
990,137 (Footnote 1)
12. CHECK IF THE AGGREGATE AMOUNT EXCLUDES CERTAIN SHARES
[]
___________________________________________________________
13. PERCENT OF CLASS REPRESENTED BY ROW 11
8.65%
14. TYPE OF REPORTING PERSON
IN
_______________________________________________________
Item 1. SECURITY AND ISSUER
This statement constitutes Amendment #2 to the schedule 13d
filed January 15, 2015. Except as specifically set forth
herein, the Schedule 13d remains unmodified.
ITEM 4. PURPOSE OF TRANSACTION
See Ex-99 - Letter to the Corporate Secretary.
ITEM 5. INTEREST IN SECURITIES OF THE ISSUER
(a) As per the N-CSR filed on February 26,2014, there were 11,441,022 shares
of common stock outstanding as of December 31, 2013. The percentages set forth
herein were derived using such number. Phillip Goldstein, Andrew Dakos and
Steven Samuels own Bulldog Investors, LLC, a registered investment advisor.
As of February 23, 2015, Bulldog Investors, LLC is deemed to be the beneficial
owner of 990,137 shares of RIT (representing 8.65% of RIT's outstanding
shares) solely by virtue of Bulldog Investors LLC's power to direct the vote
of, and dispose of, these shares. These 990,137 shares of RIT include 512,720
shares (representing 4.48% of RIT's outstanding shares) that are beneficially
owned by the following entities over which Messrs. Goldstein, Dakos and
Samuels exercise control: Opportunity Partners LP, Calapasas West Partners
LP, Full Value Special Situations Fund, LP, Full Value Offshore Fund, Ltd.,
Full Value Partners, LP, Opportunity Income Plus, LP, and MCM Opportunity
Partners, LP (collectively,"Bulldog Investors Group of Funds").
Bulldog Investors Group of Funds may be deemed to constitute a group. All
other shares included in the aforementioned 990,137 shares of RIT beneficially
owned by Bulldog Investors, LLC (solely by virtue of its power to sell or
direct the vote of these shares) are also beneficially owned by clients
of Bulldog Investors, LLC who are not members of any group. The total number of
these "non-group" shares is 477,417 (representing 4.17% of RIT's
outstanding shares).
(b) Bulldog Investors, LLC has sole power to dispose of and vote 512,720 shares.
Bulldog Investors, LLC has shared power to dispose of and vote 477,417 shares.
Certain of Bulldog Investors, LLC's clients (none of whom beneficially own more
than 5% of RIT's shares) share this power with Bulldog Investors, LLC. Messrs.
Goldstein, Dakos and Samuels are control persons of Bulldog Investors, LLC.
c) Since the last filing on 2/4/15 the following shares of RIT were purchased:
Date: Shares: Price:
02/04/15 2,300 13.3639
02/05/15 1,061 13.4400
02/11/15 25,400 13.0120
02/12/15 1,200 13.1300
02/12/15 16,695 13.1341
02/13/15 6,289 13.0528
02/17/15 4,000 13.0863
02/17/15 30,229 13.1010
02/18/15 25,000 13.0368
02/20/15 24,880 12.9599
02/20/15 5,800 13.0200
02/23/15 15,634 13.0906
02/23/15 500 13.1000
d) Clients of Bulldog Investors, LLC are entitled to receive any dividends or
sales proceeds.
e) N/A
ITEM 6. CONTRACTS,ARRANGEMENTS,UNDERSTANDINGS OR RELATIONSHIPS
WITH RESPECT TO SECURITIES OF THE ISSUER.
N/A
ITEM 7. MATERIAL TO BE FILED AS EXHIBITS
See exhibit 99
After reasonable inquiry and to the best of my knowledge
and belief, I certify that the information set forth in this
statement is true, complete and correct.
Dated: 2/24/2015
By: /S/ Phillip Goldstein
Name: Phillip Goldstein
By: /S/ Andrew Dakos
Name: Andrew Dakos
By: /S/ Steven Samuels
Name: Steven Samuels
Bulldog Investors, LLC
By: /s/ Andrew Dakos
Andrew Dakos, Member
Footnote 1: The reporting persons disclaim beneficial ownership except
to the extent of any pecuniary interest therein.