GDL FUND — Director's Dealing 2020

May 27, 2020

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: GDL FUND (GDL)
CIK: 0001378701
Period of Report: 2020-05-22

Reporting Person: GABELLI MARIO J (Director, 10% Owner, Control Person of Adviser)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2020-05-22	Common Shares, Par Value $0.001	P	10987	$8.3088	Acquired	2530825.31	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Shares, Par Value $0.001	1734490.09	Indirect
Common Shares, Par Value $0.001	7174.2	Indirect
Common Shares, Par Value $0.001	222252	Indirect
Common Shares, Par Value $0.001	55436.88	Indirect
Common Shares, Par Value $0.001	40672.51	Indirect
Common Shares, Par Value $0.001	52730	Indirect

Footnotes

F1: Total includes shares acquired through dividend reinvestment subsequent to the initial purchase.

F2: The shares reported reflect the total shares owned by Associated Capital Group, Inc. (AC). Mario J. Gabelli is the Executive Chairman and controlling shareholder of AC. Mr. Gabelli has less than a 100% interest in AC and disclaims beneficial ownership of the shares held by it which are in excess of his indirect pecuniary interest.

F3: The shares reported reflect the total shares owned by Gabelli & Company Investment Advisers, Inc. (GCIA), a majority owned subsidiary of GAMCO. Mr. Gabelli has less than a 100% interest in GCIA and disclaims beneficial ownership of the shares held by this entity which are in excess of his indirect pecuniary interest.

F4: The shares reported reflect the total shares owned by GGCP, Inc. (GGCP). Mario J. Gabelli is the Chief Executive Officer, a director, and the controlling shareholder of GGCP. Mr. Gabelli has less than a 100% interest in GGCP and disclaims beneficial ownership of the shares held by it which are in excess of his indirect pecuniary interest.

F5: The shares reported reflect the total shares owned by MJG IV Limited Partnership, a limited partnership for which Mr. Gabelli serves as a general partner. Mr. Gabelli has less than a 100% interest in the entity and disclaims beneficial ownership of the shares held by this entity which are in excess of his indirect pecuniary interest.

F6: The shares reported reflect the total shares owned by GPJ Retirement Partners, LLC, a limited liability company. Mr. Gabelli has less than a 100% interest in the entity and disclaims beneficial ownership of the shares held by this entity which are in excess of his indirect pecuniary interest.

F7: The shares reported reflect the total shares owned by GAMCO Investors, Inc. (GAMCO). Mario J. Gabelli is the Chairman, Chief Executive Officer, and controlling shareholder of GAMCO. Mr. Gabelli has less than a 100% interest in GAMCO and disclaims beneficial ownership of the shares held by it which are in excess of his indirect pecuniary interest.