Special Opportunities Fund, Inc. N-CSRS

Exhibit 99.19(A)

 

Special Opportunities Fund, Inc.

January 30, 2026

19a-1 Notice

 

The Special Opportunities Fund, Inc. (the “Fund”) previously announced that the Board of Directors had approved a Managed Distribution Plan (MDP). Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2025. On January 30, 2026, the monthly distribution under the MDP of $0.1087 per share will be paid to stockholders of record on January 20, 2026.

 

As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.

 

The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

 

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.

 

The following table sets forth an estimate of the sources of the January 30, 2026, distribution and of distributions paid in the current fiscal year:

 

Distribution Estimates  January 2026   Fiscal Year-to-date (YTD)1 

Source

  Per Share Amount   Percent of Current Distribution   Per Share Amount   Percent of Fiscal Year Distributions 
Net Investment Income  $0.0256   23.56%  $0.0256   23.56%
Net Realized Short-Term Capital Gains  $0.0105   9.65%  $0.0105   9.65%
Net Realized Long-Term Capital Gains  $0.0000   00.00%  $0.0000   00.00%
Return of Capital  $0.0726   66.79%  $0.0726   66.79%
Total Distribution  $0.1087   100.00%  $0.1087   100.00%

 

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

 

Average Annual Total Return for the 5-year period ended on December 31, 20252   10.07%
Current Annualized Distribution Rate (current fiscal year)3   7.02%
Current Fiscal Year Cumulative Total Return4   11.59%
Cumulative Distribution Rate (current fiscal year)5   8.08%

 

 

 

1The Fund’s current fiscal year began on January 1, 2026

 

2Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.

 

 

 

3The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of December 31, 2025, annualized as a percentage of the Fund’s NAV at the same date.

 

4Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2025, through December 31, 2025, including distributions paid and assuming reinvestment of those distributions.

 

5Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2025, through December 31, 2025) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of December 31, 2025.

 

You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.

 

The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

 

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.

 

 

 

Special Opportunities Fund, Inc.

February 27, 2026

19a-1 Notice

 

Special Opportunities Fund, Inc. (the “Fund”) announced that the Board of Directors has approved a Managed Distribution Plan (MDP). Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2025. On February 27, 2026, the monthly distribution under the MDP of $0.1087 per share will be paid to stockholders of record on February 17, 2026.

 

As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.

 

The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

 

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.

 

The following table sets forth an estimate of the sources of the February 27, 2026, distribution and of distributions paid in the current fiscal year:

 

Distribution Estimates  February 2026   Fiscal Year-to-date (YTD)1 

Source

  Per Share Amount   Percent of Current Distribution   Per Share Amount   Percent of Fiscal Year Distributions 
Net Investment Income  $0.0324   29.79%  $0.0494   22.74%
Net Realized Short-Term Capital Gains  $0.0118   10.89%  $0.0220   10.10%
Net Realized Long-Term Capital Gains  $0.0000   00.00%  $0.0000   00.00%
Return of Capital  $0.0645   59.32%  $0.1460   67.16%
Total Distribution  $0.1087   100.00%  $0.2174   100.00%

 

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

 

Average Annual Total Return for the 5-year period ended on January 31, 20262   9.19%
Current Annualized Distribution Rate (current fiscal year)3   7.85%
Current Fiscal Year Cumulative Total Return4   1.47%
Cumulative Distribution Rate (current fiscal year)5   0.67%

 

 

 

1The Fund’s current fiscal year began on January 1, 2026

 

2Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.

 

 

 

3The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of January 31, 2026, annualized as a percentage of the Fund’s NAV at the same date.

 

4Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2026, through January 31, 2026, including distributions paid and assuming reinvestment of those distributions.

 

5Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2026, through January 31, 2026) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of December 31, 2025.

 

You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.

 

The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

 

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.

 

 

 

Special Opportunities Fund, Inc.

March 31, 2026

19a-1 Notice

 

Special Opportunities Fund, Inc. (the “Fund”) announced that the Board of Directors has approved a Managed Distribution Plan (MDP). Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2025. On February 27, 2026, the monthly distribution under the MDP of $0.1087 per share will be paid to stockholders of record on February 17, 2026.

 

As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.

 

The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

 

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.

 

The following table sets forth an estimate of the sources of the March 31, 2026, distribution and of distributions paid in the current fiscal year:

 

Distribution Estimates  March 2026   Fiscal Year-to-date (YTD)1 

Source

  Per Share Amount   Percent of Current Distribution   Per Share Amount   Percent of Fiscal Year Distributions 
Net Investment Income  $0.0608   55.93%  $0.1188   36.43%
Net Realized Short-Term Capital Gains  $0.0000   0.00%  $0.0223   6.84%
Net Realized Long-Term Capital Gains  $0.0341   31.37%  $0.0341   10.46%
Return of Capital  $0.0138   12.70%  $0.1509   46.27%
Total Distribution  $0.1087   100.00%  $0.3261   100.00%

 

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

 

Average Annual Total Return for the 5-year period ended on February 28, 20262   8.28%
Current Annualized Distribution Rate (current fiscal year)3   4.00%
Current Fiscal Year Cumulative Total Return4   0.58%
Cumulative Distribution Rate (current fiscal year)5   0.65%

 

 

 

1The Fund’s current fiscal year began on January 1, 2026

 

2Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.

 

 

 

3The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of February 28, 2026, annualized as a percentage of the Fund’s NAV at the same date.

 

4Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2026, through February 28, 2026, including distributions paid and assuming reinvestment of those distributions.

 

5Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2026, through February 28, 2026) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of December 31, 2025.

 

You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.

 

The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

 

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.

 

 

 

Special Opportunities Fund, Inc.

April 30, 2026

19a-1 Notice

 

Special Opportunities Fund, Inc. (the “Fund”) announced that the Board of Directors has approved a Managed Distribution Plan (MDP). Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2025. On April 30, 2026, the monthly distribution under the MDP of $0.1087 per share will be paid to stockholders of record on April 21, 2026.

 

As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.

 

The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

 

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.

 

The following table sets forth an estimate of the sources of the April 30, 2026, distribution and of distributions paid in the current fiscal year:

 

Distribution Estimates  April 2026   Fiscal Year-to-date (YTD)1 

Source

  Per Share Amount   Percent of Current Distribution   Per Share Amount   Percent of Fiscal Year Distributions 
Net Investment Income  $0.0771   70.93%  $0.1959   45.05%
Net Realized Short-Term Capital Gains  $0.0000   0.00%  $0.0223   5.13%
Net Realized Long-Term Capital Gains  $0.0182   16.74%  $0.0523   12.03%
Return of Capital  $0.0134   12.33%  $0.1643   37.79%
Total Distribution  $0.1087   100.00%  $0.4348   100.00%

 

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

 

Average Annual Total Return for the 5-year period ended on March 31, 20262   6.92%
Current Annualized Distribution Rate (current fiscal year)3   2.89%
Current Fiscal Year Cumulative Total Return4   -4.52%
Cumulative Distribution Rate (current fiscal year)5   0.71%

 

 

 

1The Fund’s current fiscal year began on January 1, 2026

 

2Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.

 

 

 

3The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of March 31, 2026, annualized as a percentage of the Fund’s NAV at the same date.

 

4Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2026, through March 31, 2026, including distributions paid and assuming reinvestment of those distributions.

 

5Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2026, through March 28, 2026) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of December 31, 2025.

 

You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.

 

The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

 

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.

 

 

 

Special Opportunities Fund, Inc.

May 31, 2026

19a-1 Notice

 

Special Opportunities Fund, Inc. (the “Fund”) announced that the Board of Directors has approved a Managed Distribution Plan (MDP). Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2025. On May 29, 2026, the monthly distribution under the MDP of $0.1087 per share will be paid to stockholders of record on May 19, 2026.

 

As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.

 

The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

 

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.

 

The following table sets forth an estimate of the sources of the May 29, 2026, distribution and of distributions paid in the current fiscal year:

 

Distribution Estimates  May 2026   Fiscal Year-to-date (YTD)1 

Source

  Per Share Amount   Percent of Current Distribution   Per Share Amount   Percent of Fiscal Year Distributions 
Net Investment Income  $0.0545   50.14%  $0.2504   46.07%
Net Realized Short-Term Capital Gains  $0.0000   0.00%  $0.0223   4.10%
Net Realized Long-Term Capital Gains  $0.0542   49.86%  $0.1065   19.60%
Return of Capital  $0.0000   0.00%  $0.1643   30.23%
Total Distribution  $0.1087   100.00%  $0.5435   100.00%

 

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

 

Average Annual Total Return for the 5-year period ended on April 30, 20262   7.35%
Current Annualized Distribution Rate (current fiscal year)3   2.06%
Current Fiscal Year Cumulative Total Return4   0.92%
Cumulative Distribution Rate (current fiscal year)5   0.68%

 

 

 

1The Fund’s current fiscal year began on January 1, 2026

 

2Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.

 

 

 

3The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of April 30, 2026, annualized as a percentage of the Fund’s NAV at the same date.

 

4Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2026, through April 30, 2026, including distributions paid and assuming reinvestment of those distributions.

 

5Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2026, through April 30, 2026) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of December 31, 2025.

 

You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.

 

The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

 

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.

 

 

 

Special Opportunities Fund, Inc.

June 30, 2026

19a-1 Notice

 

Special Opportunities Fund, Inc. (the “Fund”) announced that the Board of Directors has approved a Managed Distribution Plan (MDP). Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2025. On June 30, 2026, the monthly distribution under the MDP of $0.1087 per share will be paid to stockholders of record on June 16, 2026.

 

As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.

 

The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

 

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.

 

The following table sets forth an estimate of the sources of the June 30, 2026, distribution and of distributions paid in the current fiscal year:

 

Distribution Estimates  June 2026   Fiscal Year-to-date (YTD)1 

Source

  Per Share Amount   Percent of Current Distribution   Per Share Amount   Percent of Fiscal Year Distributions 
Net Investment Income  $0.0492   45.26%  $0.2996   45.94%
Net Realized Short-Term Capital Gains  $0.0000   0.00%  $0.0223   3.42%
Net Realized Long-Term Capital Gains  $0.0227   20.88%  $0.1292   19.81%
Return of Capital  $0.0368   33.85%  $0.2011   30.83%
Total Distribution  $0.1087   100.00%  $0.6522   100.00%

 

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

 

Average Annual Total Return for the 5-year period ended on May 31, 20262   7.01%
Current Annualized Distribution Rate (current fiscal year)3   1.65%
Current Fiscal Year Cumulative Total Return4   0.99%
Cumulative Distribution Rate (current fiscal year)5   0.68%

 

 

 

1The Fund’s current fiscal year began on January 1, 2026

 

2Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.

 

 

 

3The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of May 31, 2026, annualized as a percentage of the Fund’s NAV at the same date.

 

4Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2026, through May 31, 2026, including distributions paid and assuming reinvestment of those distributions.

 

5Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2026, through May 31, 2026) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of December 31, 2025.

 

You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.

 

The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

 

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.