semi-annual report february 28, 2021

Semi-Annual Report

February 28, 2021

INVESTMENT PRODUCTS: NOT FDIC INSURED • NO BANK GUARANTEE • MAY LOSE VALUE

B A R R E T T

O P P O R T U N I T Y F U N D , I N C .

Semi-Annual Report • February 28, 2021

Fund Objectives The Fund seeks to achieve above average long-term capital appreciation. Currentincome is a secondary objective. The Fund invests primarily in common stocks andsecurities convertible into or exchangeable for common stock such as convertiblepreferred stock or convertible debt securities.

What’s Inside Letter from the Chairperson 1

Manager Overview 1

Fund at a Glance 5

Fund Expenses 6

Schedule of Investments 7

Statement of Assets & Liabilities 9

Statement of Operations 10

Statements of Changes in Net Assets 11

Financial Highlights 12

Notes to Financial Statements 13

Additional Information 21

Important Tax Information 23

B A R R E T T


Dear Shareholder,

We are pleased to provide the semi-annual report of the Barrett Opportunity Fund,Inc.1 (the “Fund”) for the six-month period ended February 28th, 2021.

The management team at Barrett Asset Management, LLC (“Barrett”) has prepared theenclosed Manager’s Overview, which includes a brief market overview, as well as aperformance review. I urge you to read it as well as the accompanying financialstatements. A detailed summary of the Fund’s performance and other pertinentinformation are also included in this report. I am sure you will find it informativeand useful.

On behalf of the Directors and the officers of the Fund, I thank you for your ongoingconfidence in the Fund and its investment policies.

Sincerely,

David H. KochmanChairpersonMarch 31, 2021

1 The Fund was formerly known as the Salomon Brothers Opportunity Fund Inc. The Fund name,investment manager and certain investment policies were changed effective December 1, 2006.

Market Overview

What a difference a year can make. In the spring of 2020, the world abruptly fell into aglobal pandemic so severe that most countries were forced into a holding pattern withno end in sight. Fast forward twelve months later, with spring of 2021 around thecorner, global citizens are now embraced with hope that an economic recovery is fullyunderway. In fact, according to the Organization for Economic Co-operation andDevelopment (OECD), worldwide Gross Domestic Product (GDP) growth is projectedto be 5.6% in 2021, with the United States leading the way and expected to grow at6.5% after falling 3.5% in the previous year.

The U.S. economic recovery is being lifted by several important factors, with COVID-19vaccine rollouts being a major one. Since November 2020, there have been threevaccines (independently developed by Pfizer, Moderna and more recently, Johnson &Johnson) that received emergency approval from the U.S. Food & Drug Administration(FDA). The U.S. government immediately pushed forward COVID-19 vaccinedistribution and administration following these announcements. Despite somebottlenecks at the state and local levels, Pantheon Macroeconomics is now estimating

Letter from theChairperson

ManagerOverview

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that 20% of the U.S. population have had received at least one shot. At this rate andincluding those who are already naturally immune from previously contractingCOVID-19, herd immunity (defined as the point in time when a large part of the U.S.population is immune to a specific disease) could potentially be reached by end of Q2.

The ongoing vaccine rollout is attributable to massive fiscal stimulus plans that haveallowed for such vaccines to be accessible and free of charge to Americans. The newBiden administration continues to pump an unprecedented amount of liquidity intothe economy with the latest program valued at $1.9 Trillion. This newest package willpush another $400+ Billion directly into the bank accounts of Americans, as well ashelp with rental assistance and extend unemployment insurance to name a few aspectsof the bill. At the same time, the Federal Reserve remains consistent with its extremelyaccommodative monetary policy and has communicated they will not imprudentlyreact to short-term spikes in data.

One can see the potential for a successful economic recovery when adding up the threeabove ingredients: viable healthcare solutions, meaningful fiscal help, and dovishmonetary policy. Accordingly, the stock market reacted positively with the S&P 500having appreciated 5.63% for the past three months as of February 28, 2021.

We remain relatively optimistic on the economic outlook but recognize there aregrowing concerns to monitor during the recovery period. Top of the list is thepossibility of major tax reform, which seems inevitable as debt (via issuing U.S.Treasuries) cannot be the only option to finance the huge amounts of governmentspending. Any increase in personal income tax rates will reduce consumers’discretionary buying power. At the same time, a higher corporate tax rate will impactpotential earnings growth and therefore valuation levels for stocks. On this point, thebroader market (as measured by the S&P 500) is valued at an above average price-to-earnings (P/E)(1) multiple of 23x based on 2021 earnings estimates. There appearslittle room for error therefore any headwinds, whether it is potentially higher tax ratesor a resurgence of COVID-19 cases, could easily dampen momentum. Further,inflation expectations could increase as there is clear pent-up demand with consumerseager to spend. As soon as lockdown restrictions are lifted, we will likely see a pop inactivity within the service segment of our economy. We expect the Fed to monitorinflation rates against its targets and will not change its stance for another 18+ months.However, the U.S. Treasury yield curve may continue to rise to reflect the ongoingeconomic recovery and to signal potentially higher inflation expectations. This willcontinue to increase volatility in the stock market despite the Fed’s steady hand.

Portfolio and Performance Review

During the six-month period ending February 28, 2021, the Fund appreciated 10.74%for the quarter compared to a gain of 18.57% for the Lipper Large Cap Value FundIndex(2) and a 9.74% gain for the S&P 500. During the six-month period, the bestperforming sectors of the S&P 500 were Energy, Financials, and Industrials. The worstperforming sectors in the market were Consumer Staples and Utilities. Technologyand Consumer Discretionary are the largest sector weightings in the Fund.

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The highest contributing sectors to the Fund’s performance during the six-month periodwere Financials, Energy, and Communication Services. Consumer Staples and Utilitieswere the largest detractors to the Fund’s performance. On an individual company basis,Royal Dutch Shell, Bank of New York, and Jefferies Financial Group were the largestcontributors to the Fund’s performance. Apple, Murphy USA, and Fidelity NationalInformation Services were the biggest detractors to the Fund’s performance.

During the six-month period ending February, we initiated a new position in FleetCorTechnologies, a leader provider of digital payment solutions for businesses. Inaddition, we exited our position in Berkshire Hathaway and continued to trim ourpositions in Bank of New York, General Dynamic, as well as Alphabet. During thesix-month period, we decided to write covered calls on Apple, Bank of New York, andGeneral Dynamics. As a result of the trades, the fund’s top five holdings are down to49.1% of equities.

Investment Outlook

We are constructive on the outlook for economic growth to improve as vaccinationlevels continue to improve and consumers return to more normalized activities. Wehave seen a shift from growth-oriented names leading equity market performance tonow more value-oriented names leading the major indices. With the outlook forinterest rates to continue to gradually rise, we would anticipate value-oriented namesto continue to perform well. The holdings in the fund are well positioned to benefitfrom these trends.

We appreciate your continued interest in the Fund.

Sincerely,

Robert Milnamow E. Wells Beck, CFAPortfolio Manager Portfolio Manager

(1) Price to earnings ratio (P/E) is the ratio of a company’s share (stock) price to the company’s earningsper share.

(2) The Lipper Large-Cap Value Funds Index includes funds that, by portfolio practice, invest at least 75% oftheir equity assets in companies with market capitalizations (on a three year weighted basis) aboveLipper’s U.S. Diversified Equity large-cap floor.

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Earnings growth is not representative of the Fund’s future performance.

Past performance is not a guarantee of future results.

The outlook, views, and opinions presented are those of the Adviser as of February 28, 2021.These are not intended to be a forecast of future events, a guarantee of future results, orinvestment advice.

Must be preceded or accompanied by a prospectus.

Mutual fund investing involves risk. Principal loss is possible. The Fund is non-diversified,which means that it can invest a higher percentage of its assets in any one issuer. Investing ina non-diversified fund may entail greater risks than is normally associated with more widelydiversified funds. Small- and Medium- capitalization companies tend to have limitedliquidity and greater price volatility than large-capitalization companies. Investing in foreignsecurities is subject to certain risks not associated with domestic investing, such as currencyfluctuations and changes in political and economic conditions. These risks are magnified inemerging or developing markets. Some securities held by the fund may be illiquid and canbe difficult to value and sell.

The S&P 500® Index is a capitalization weighted index of five hundred large capitalizationstocks, which is designed to measure broad domestic securities markets.

Investors cannot invest directly in an index.

Fund holdings and sector allocations are subject to change and should not be considered arecommendation to buy or sell any security. For a complete list of portfolio holdings, pleaserefer to the Schedule of Investments provided in this report.

The Barrett Opportunity Fund is distributed by Quasar Distributors, LLC.

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5

Manufacturing53.3%

Information13.9%

Finance and Insurance11.4%

Mining, Quarrying, andOil and Gas Extraction

7.1%

Retail Trade6.8%

Wholesale Trade3.7%

Real Estate and Rental and Leasing3.3%

Administrative Support, Waste Management0.5%

Fund at a Glance (Unaudited)Top Ten Holdings – as of 2/28/2021

(As a percentage of Total Investments)___________________________________

General Dynamics Corp. 12.8%The Bank of New York Mellon Corp. 10.7%Koninklijke Philips Electronics NV – NY Registered Shares – ADR 10.2%Apple, Inc. 7.5%Microsoft Corp. 7.4%Royal Dutch Shell PLC – Class A – ADR 7.1%Alphabet, Inc. – Class C 5.9%Murphy USA Inc. 4.9%Automatic Data Processing, Inc. 4.7%Jefferies Financial Group Inc. 3.7%

Sector Weightings – as of 2/28/2021(As a percentage of Total Investments)___________________________________

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Fund Expenses (Unaudited)

ExampleAs a shareholder of the Fund, you may incur two types of costs: (1) transaction costs and (2) ongoing costs,including management fees and other Fund expenses. This example is intended to help you understand yourongoing costs (in dollars) of investing in the Fund and to compare these costs with the ongoing costs of investing inother mutual funds.

This example is based on an investment of $1,000 invested on September 1, 2020, and held for the six months endedFebruary 28, 2021.

Actual Expenses

The row of the table below titled “Actual Barrett Opportunity Fund, Inc. Expenses” provides information aboutactual account values and actual expenses. You may use the information provided in this table, together with theamount you invested, to estimate the expenses that you paid over the period. To estimate the expenses you paid onyour account, divide your ending account value by $1,000 (for example, an $8,600 ending account value divided by$1,000 = 8.6), then multiply the result by the number under the heading entitled “Expenses Paid During the Period.”

Hypothetical Example for Comparison Purposes

The row of the table below titled “Hypothetical Expenses” provides information about hypothetical account valuesand hypothetical expenses based on the actual expense ratio and an assumed rate of return of 5.00% per year beforeexpenses, which is not the Fund’s actual return. The hypothetical account values and expenses may not be used toestimate the actual ending account balance or expenses you paid for the period. You may use the informationprovided in this table to compare the ongoing costs of investing in the Fund and other funds. To do so, compare the5.00% hypothetical example relating to the Fund with the 5.00% hypothetical examples that appear in theshareholder reports of the other funds.

Please note that the expenses shown in the table below are meant to highlight your ongoing costs only and do notreflect any transactional costs. Therefore, the table is useful in comparing ongoing costs only, and will not help youdetermine the relative total costs of owning different funds. In addition, if these transaction costs were included,your costs would have been higher.

Expenses PaidBeginning Ending During the Period*Account Account September 1, 2020 toValue Value February 28, 2021_________ ________ ___________________

Actual Barrett Opportunity Fund, Inc. Expenses $1,000.00 $1,107.00 $6.22

Hypothetical Expenses(5% return per year before expenses) $1,000.00 $1,019.00 $5.96* Expenses are equal to the Fund’s annualized six-month expense ratio of 1.19%, multiplied by the average account value over theperiod, multiplied by 181/365 (to reflect the one-half year period).

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Schedule of InvestmentsFebruary 28, 2021 (Unaudited)

Shares Value________ _______COMMON STOCKS - 96.24%

Administrative and Support Services - 0.51%

1,000 Fleetcor Technologies, Inc. $ 277,310___________

Beverage and Tobacco Product Manufacturing - 2.36%

10,000 PepsiCo., Inc. 1,291,900___________

Building Material and Garden Equipment - 1.88%

4,000 The Home Depot, Inc. 1,033,360___________

Chemical Manufacturing - 8.32%

12,000 Abbott Laboratories 1,437,36012,000 AbbVie, Inc. 1,292,8804,000 International Flavors

& Fragrances, Inc. 542,0405,000 Johnson & Johnson 792,30015,000 Pfizer, Inc. 502,350___________

4,566,930___________

Computer and Electronic Product Manufacturing - 16.33%

1,600 Alphabet, Inc. - Class C (a) 3,258,97634,000 Apple, Inc. (b) 4,122,8403,500 Thermo Fisher Scientific, Inc. 1,575,280___________

8,957,096___________

Credit Intermediation and Related Activities - 10.72%

139,471 The Bank of New York Mellon Corp. (b) 5,880,097___________

Shares Value________ _______

Data Processing, Hosting and Related Services - 6.52%

15,000 Automatic Data Processing, Inc. $ 2,610,300

7,000 Fidelity National Information Services, Inc. 966,000___________

3,576,300___________

Electrical Equipment, Appliance, and Component - 10.20%

102,854 Koninklijke Philips ElectronicsNV - NY Registered Shares - ADR 5,595,258___________

Merchant Wholesalers, Durable Goods - 3.71%

70,000 Jefferies Financial Group, Inc. 2,032,800___________

Motor Vehicle and Parts Dealers - 4.96%

21,825 Murphy USA, Inc. (a) 2,720,486___________

Nonmetallic Mineral Product Manufacturing - 1.60%

5,000 3M Co. 875,300___________

Oil and Gas Extraction - 7.11%

95,100 Royal Dutch Shell PLC - Class A - ADR 3,901,953___________

Petroleum and Coal Products Manufacturing - 1.80%

60,600 Murphy Oil Corp. 989,598___________

Publishing Industries (except Internet) - 7.41%

17,500 Microsoft Corp. 4,066,650___________

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The accompanying notes are an integral part of these financial statements.

B A R R E T T


Schedule of Investments (continued)February 28, 2021 (Unaudited)

Shares Value________ _______COMMON STOCKS(continued)

Transportation Equipment Manufacturing - 12.81%

43,000 General Dynamics Corp. (b) $ 7,029,210___________Total Common Stocks (Cost $10,653,298) 52,794,248___________

REAL ESTATE INVESTMENT TRUSTS (REITs) - 3.27%

Real Estate - 3.27%54,985 Rayonier, Inc. 1,794,711___________

Total Real Estate Investment Trusts (Cost $295,418) 1,794,711___________

SHORT-TERMINVESTMENTS - 0.73%

Money Market Funds - 0.73%399,603 Fidelity Institutional Money

Market Fund - Government Portfolio - Class I, 0.01% (c) 399,603___________Total Short-Term Investments (Cost $399,603) 399,603___________Total Investments (Cost $11,348,319) - 100.24% 54,988,562___________Liabilities in Excess of Other Assets - (0.24)% (129,197)___________Total Net Assets - 100.00% $54,859,365______________________

Percentages stated are a percentage of net assets.ADR - American Depository Receipt(a) Non-income producing security.(b) A portion of this security may be subject to call options written

and is pledged as collateral for options written. The aggregatevalue of these securities as of February 28, 2021 was $2,562,070.

(c) Rate shown is the 7-day effective yield as of February 28, 2021.

Schedule Of Written Options

Number ofContracts Value__________ _______

Call Options30 Apple, Inc.

Expiration: January 2022,Exercise Price: $150.00 $ 22,200

250 Bank of New York Mellon Corp.Expiration: January 2022, Exercise Price: $50.00 58,750

70 General Dynamics Corp.Expiration: January 2022,Exercise Price: $180.00 64,400________Total Options Written (Premiums Received $128,396) $145,350________________

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Statement of Assets & LiabilitiesFebruary 28, 2021 (Unaudited)

ASSETS:Investments, at value (cost $11,348,319) $54,988,562Dividends and interest receivable 72,802Other assets 14,932__________Total Assets 55,076,296__________

LIABILITIES:Written options, at value (Premium received $128,396) 145,350Payable to adviser 29,897Payable to directors 5,437Other accrued expenses 36,247__________Total Liabilities 216,931__________

NET ASSETS $54,859,365____________________

NET ASSETS CONSIST OF:Capital stock $ 9,542,654Total distributable earnings 45,316,711__________Total Net Assets $54,859,365____________________

Shares outstanding 2,162,974Net asset value, offering price and redemption price per share (15,000,000 shares authorized, $0.01 par value) $ 25.36____________________

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Statement of OperationsPeriod Ended February 28, 2021 (Unaudited)

INVESTMENT INCOME:Dividend income* $ 528,308Interest income 38_________Total investment income 528,346_________

EXPENSES:Investment advisory fees (see Note 2) 183,412Administration fees 25,989Directors’ fees and expenses 19,909Transfer agent fees and expenses 15,033Fund accounting fees 14,029Federal and state registration fees 13,045Insurance fees 12,038Legal fees 10,166Audit fees 8,870Custody fees 3,235Reports to shareholders 2,475Other 3,907_________Total expenses 312,108_________Net investment income 216,238_________

REALIZED AND UNREALIZED GAIN (LOSS) ON INVESTMENTS:Net realized gain on:Investments 2,279,942Written options 76,348_________

Total net realized gain 2,356,290_________Net change in unrealized appreciation/depreciation on:Investments 2,886,424Written options 56,914_________

Total net change in unrealized appreciation/depreciation 2,943,338_________Net realized and unrealized gain on investments 5,299,628_________NET INCREASE IN NET ASSETS RESULTING FROM OPERATIONS $5,515,866__________________

* Net of $9,315 of foreign taxes withheld.

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Statements of Changes in Net Assets

Period Ended February 28, 2021 Year Ended(Unaudited) August 31, 2020_________________ _______________

OPERATIONS:Net investment income $ 216,238 $ 580,871Net realized gain on:Investments 2,279,942 1,959,169Written options 76,348 76,378

Change in net unrealized appreciation/depreciation on:Investments 2,886,424 (170,774)Written options 56,914 (94,246)___________ ___________

Net increase/decrease in net assets resulting from operations 5,515,866 2,351,398___________ ___________

DIVIDENDS AND DISTRIBUTIONS TO SHAREHOLDERS:Net dividends and distributions (3,247,915) (5,733,674)___________ ___________Total distributions (3,247,915) (5,733,674)___________ ___________

CAPITAL SHARE TRANSACTIONS:Shares sold 8,802 17,332Shares issued in reinvestment of dividends 1,951,475 3,642,296Shares redeemed (1,842,453) (5,304,006)___________ ___________Net increase (decrease) in net assetsfrom capital share transactions 117,824 (1,644,378)___________ ___________

TOTAL INCREASE (DECREASE) IN NET ASSETS 2,385,775 (5,026,654)___________ ___________

NET ASSETS:Beginning of period 52,473,590 57,500,244___________ ___________End of period $54,859,365 $52,473,590___________ ______________________ ___________

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Financial Highlights

Period EndedFebruary 28,

2021 Year Ended August 31,(Unaudited) 2020 2019 2018 2017 2016_____________ _____ _____ _____ _____ _____

Per Share Data:Net asset value, beginning of year $24.33 $25.77 $30.75 $29.62 $31.14 $31.52______ ______ ______ ______ ______ ______

Income (loss) from investment operations:Net investment income 0.08 0.29 0.29 0.38 0.23 0.33Net realized and unrealizedgain (loss) on investments 2.48 0.85 (1.62) 2.56 5.31 2.57______ ______ ______ ______ ______ ______Total from investment operations 2.56 1.14 (1.33) 2.94 5.54 2.90______ ______ ______ ______ ______ ______

Less distributions:Net investment income (0.22) (0.33) (0.25) (0.36) (0.33) (0.28)Net realized gain on investments (1.31) (2.25) (3.40) (1.45) (6.73) (3.00)______ ______ ______ ______ ______ ______Total distributions (1.53) (2.58) (3.65) (1.81) (7.06) (3.28)______ ______ ______ ______ ______ ______

Net asset value, end of year $25.36 $24.33 $25.77 $30.75 $29.62 $31.14______ ______ ______ ______ ______ ____________ ______ ______ ______ ______ ______

Total return 10.74%1 3.94% (3.27)% 10.15% 20.49% 10.45%

Supplemental data and ratios:Net assets, end of year (millions) $55 $52 $58 $65 $63 $60Ratio of net expenses to average net assets 1.19%2 1.25% 1.23% 1.13% 1.22% 1.27%Ratio of net investment income to average net assets 0.83%2 1.08% 1.09% 1.23% 0.78% 1.11%Portfolio turnover rate 1%1 1% 8% 4% 1% 6%

1 Not annualized for the six months ended February 28, 2021.2 Annualized for the six months ended February 28, 2021.

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Notes to Financial Statements (Unaudited)

1. ORGANIZATION Barrett Opportunity Fund, Inc. (“the “Fund”), a Maryland corporation organized AND in 1978, is registered as a non-diversified, open-end management investment SIGNIFICANT company under the Investment Company Act of 1940, as amended (the “1940 ACCOUNTING Act). The Fund is an investment company and accordingly follows the POLICIES investment company accounting and reporting guidance of the Financial

Accounting Standards Board (“FASB”) Accounting Codification Topic 946“Financial Services – Investment Companies.” The Fund’s investment objectiveis to achieve above average long-term capital appreciation. Current income is asecondary objective.

The following are significant accounting policies consistently followed by theFund and are in conformity with generally accepted accounting principles in theUnited States of America (“GAAP”).

(a) Investment ValuationEquity securities, including common stocks and REITs, for which marketquotations are available are valued at the last reported sales price or officialclosing price on the primary market or exchange on which they trade.

Redeemable securities issued by open-end, registered investment companies,including money market funds, are valued at the net asset value (“NAV”) ofsuch companies for purchase and / or redemption orders placed on that day.

Exchange traded options, including options written, are valued at the compositeprice, using the National Best Bid and Offer quotes (“NBBO”). NBBO consists ofthe highest bid price and lowest ask price across any of the exchanges on whichan option is quoted, thus providing a view across the entire U.S. optionsmarketplace. Specifically, composite pricing looks at the last trades on theexchanges where the options are traded. If there are no trades for the option on agiven business day, composite option pricing calculates the mean of the highestbid price and lowest ask price across the exchanges where the option is traded.

When prices are not readily available, or are determined not to reflect fair value,such as, when the value of a security has been significantly affected by eventsafter the close of the exchange or market on which the security is principallytraded, but before the Fund calculates its net asset value, the Fund values thesesecurities at fair value as determined in accordance with procedures approvedby the Fund’s Board of Directors.

The Fund uses valuation techniques to measure fair value that are consistentwith the market approach and / or income approach, depending on the type ofthe security and the particular circumstance. The market approach uses pricesand other relevant information generated by market transactions involvingidentical or comparable securities. The income approach uses valuationtechniques to discount estimated future cash flows to present value.

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FASB Accounting Standards Codification, “Fair Value Measurements andDisclosures” Topic 820 (“ASC Topic 820”), establishes a single definition of fairvalue, creates a three-tier hierarchy as a framework for measuring fair valuebased on inputs used to value the Fund’s investments, and requires additionaldisclosure about fair value. The hierarchy of inputs is summarized below:

• Level 1 – quoted prices in active markets for identical investments as of themeasurement date

• Level 2 – other significant observable inputs (including quoted prices for similarinvestments, interest rates, prepayment speeds, credit risk, etc.)

• Level 3 – significant unobservable inputs (including the Fund’s ownassumptions in determining the fair value of investments)

Inputs refer broadly to the assumptions that market participants use to makevaluation decisions, including assumptions about risk. Inputs may include priceinformation, volatility statistics, specific and broad credit data, liquiditystatistics, and other factors. A financial instrument’s level within the fair valuehierarchy is based on the lowest level of input that is significant to the fair valuemeasurement. However, the determination of what constitutes “observable”requires significant judgment by the Fund. The Fund considers observable datato be that market data which is readily available, regularly distributed orupdated, reliable and verifiable, not proprietary, and provided by independentsources that are actively involved in the relevant market. The categorization of afinancial instrument within the hierarchy is based upon the pricing transparencyof the instrument and does not necessarily correspond to the Fund’s perceivedrisk of that instrument.

Investments whose values are based on quoted market prices in active marketsinclude listed equities, including common stocks and REITs, and certain moneymarket securities, and are classified within Level 1. Instruments that trade inmarkets that are not considered to be active, but are valued based on quotedmarket prices, dealer quotations or alternative pricing sources supported byobservable inputs, are classified within Level 2. Investments classified withinLevel 3 have significant unobservable inputs, as they trade infrequently or notat all.

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The following is a summary of the inputs used in valuing the Fund’s assetscarried at fair value as of February 28, 2021. The inputs and methodologies usedto value securities may not be an indication of the risk associated with investingin these securities.

OtherSignificant Significant

Quoted Observable UnobservablePrices Inputs Inputs

Description (Level 1) (Level 2) (Level 3) Total______________________ __________ ___________ _____________ __________AssetsCommon Stocks $52,794,248 $ — $ — $52,794,248REITs 1,794,711 — — 1,794,711Money Market Funds 399,603 — — 399,603__________ ________ _____ __________Total Investments in Securities $54,988,562 $ — $ — $54,988,562__________ ________ _____ ____________________ ________ _____ __________LiabilitiesWritten Options $ (80,950) $(64,400) $ — $ (145,350)__________ ________ _____ ____________________ ________ _____ __________

There were no transfers of securities between levels during the reporting period.The Fund did not hold any Level 3 securities during the year.

Derivative InstrumentsThe Fund may invest in derivative instruments. The use of derivatives includedwritten options. Written options are presented in the Statement ofAssets & Liabilities.

Statement of Assets & Liabilities – Values of derivative instruments as ofFebruary 28, 2021:

Liability Derivatives_____________________________________Derivatives not Statement ofaccounted for as Assets andhedging instruments Liabilities Location Value___________________ __________________ ______Equity Contracts – Options written, Options at value $145,350

The effect of derivative instruments on the Statement of Operations for the fiscalperiod ended February 28, 2021:

Derivatives not Amount of Realized Gainsaccounted for as on Derivatives Transactions_____________________________________hedging instruments Written Options___________________ _______________Equity Contracts $76,348

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B A R R E T T


Derivatives not Change in Net Unrealized Appreciationaccounted for as on Derivatives Recognized in Income_____________________________________hedging instruments Written Options___________________ _______________Equity Contracts $56,914

The Fund is not subject to any Master Netting Agreements; therefore, the Fundwas not required to offset any assets or liabilities.

(b) OptionsGAAP requires enhanced disclosures about the Fund’s derivative activities,including how such activities are accounted for and their effect on the Fund’sfinancial position and results of operations.

The Fund is subject to equity price risk in the normal course of pursuing itsinvestment objective. The Fund enters into written call options to hedge againstchanges in the value of equities. The Fund’s option component of the overallinvestment strategy is often referred to as a “buy-write” strategy (also called a“covered call” strategy), in which the Adviser (as defined below) writes (sells) acall option contract while at the same time owning an equivalent number ofshares of the underlying stock to generate moderate current income. Thewriting of call options is intended to reduce the volatility of the portfolio and toearn premium income. Written call options expose the Fund to minimalcounterparty credit risk since they are exchange traded and the exchange’sclearing house guarantees the options against default.

As the writer of a call option, the Fund has the obligation to sell the security atthe exercise price during the exercise period in the event the option is exercised.

When the Fund writes an option, an amount equal to the premium received bythe Fund is recorded as a liability and is subsequently adjusted to the currentfair value of the option written. Premiums received from writing options thatexpire unexercised are treated by the Fund on the expiration date as realizedgains from options written. The difference between the premium and theamount paid on effecting a closing purchase transaction, including brokeragecommissions, is also treated as a realized gain, or, if the premium is less than theamount paid for the closing purchase transaction, as a realized loss. If a calloption is exercised, the premium is added to the proceeds from the sale of theunderlying security or currency in determining whether the Fund has realized again or a loss. The Fund as writer of an option bears the market risk of anunfavorable change in the price of the security underlying the written option.The average notional amount for written options during the period endedFebruary 28, 2021, was $2,269,007.

(c) Security Transactions and Investment IncomeSecurity transactions are accounted for on a trade date basis. Interest income,adjusted for amortization of premium and accretion of discount, is recorded onthe accrual basis. Dividend income is recorded on the ex-dividend date.

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Non-cash dividends are recorded at the fair market value of the securitiesreceived. Under applicable tax laws, a withholding tax may be imposed oninterest, dividends, and capital gains at various rates and withholding taxes onforeign dividends have been provided for in accordance with the Fund’sunderstanding of the applicable country’s tax rules and rates. The cost ofinvestments sold is determined by use of the specific identification method forcomputing the gain/loss on the transaction. It is the Fund’s policy to recognizea loss on a worthless security once it is determined beyond a reasonable doubtthat there is no possibility of future worth. Proceeds from bankruptcysettlements will generally be recognized as a realized gain if the security is nolonger held and as a return of capital if the security is still held.

(d) Distributions to ShareholdersThe Fund will distribute any net investment income and any net realized long- orshort-term capital gains at least annually. Distributions from net realized gains forbook purposes may include short-term capital gains. All short-term capital gainsare included in ordinary income for tax purposes. Distributions to shareholders arerecorded on the ex-dividend date. The Fund may also pay a special distribution atthe end of the calendar year to comply with federal tax requirements.

(e) REIT DistributionsThe character of distributions received from REITs held by the Fund is generallycomprised of net investment income, capital gains, and return of capital. It is thepolicy of the Fund to estimate the character of distributions received fromunderlying REITs based on historical data provided by the REITs. After eachcalendar year end, REITs report the actual tax character of these distributions.Differences between the estimated and actual amounts reported by the REITs arereflected in the Fund’s records in the year in which they are reported by the REITsby adjusting related investment cost basis, capital gains and income, as necessary.

(f) Federal Income TaxesIt is the Fund’s policy to comply with the federal income and excise taxrequirements of subchapter M of the Internal Revenue Code of 1986, asamended (the “Code”), necessary to qualify as a regulated investment company.Accordingly, the Fund intends to distribute its taxable income and net realizedgains, if any, to shareholders in accordance with timing requirements imposedby the Code. Therefore, no federal income tax provision is provided in theFund’s financial statements.

As of and during the year ended August 31, 2020, the Fund did not have aliability of any unrecognized tax benefits. The Fund recognizes interest andpenalties, if any, related to uncertain tax benefits as income tax expense in theStatement of Operations. During the year, the Fund did not incur any interest orpenalties. The Fund is not subject to examination by U.S. taxing authorities fortax periods prior to 2017.

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(g) Use of EstimatesThe preparation of financial statements in conformity with GAAP requiresmanagement to make estimates and assumptions that affect the reportedamounts of assets and liabilities and disclosure of contingent assets andliabilities as the date of the financial statements and the reported amounts ofrevenues and expenses during the reporting period. Actual results could differfrom those estimates.

(h) IndemnificationIn the normal course of business the Fund enters into contracts that containgeneral indemnification clauses. The Fund’s maximum exposure under theseagreements is unknown, as this would involve future claims against the Fundthat have not yet occurred. Based on experience, the Fund expects the risk ofloss to be remote.

(i) Beneficial OwnershipThe beneficial ownership, either directly or indirectly, of more than 25% of thevoting securities of a fund creates a presumption of control of the fund, underSection 2(a)(9) of the 1940 Act. At February 28, 2021 John B. Gaguine hadcontrol of 34.60% of the outstanding shares of the Fund.

2. INVESTMENT The Fund has an Investment Advisory Agreement with Barrett Asset ADVISER Management, LLC (“Barrett Asset Management” or the “Adviser”). Under the AGREEMENT Investment Advisory Agreement, the Fund pays an advisory fee, calculated AND OTHER daily and paid monthly, in accordance with the following breakpoint schedule:TRANSACTIONS Average Daily Net Assets Annual Rate________________________ ____________WITH AFFILIATES First $1 billion 0.700%

Next $1 billion 0.675%Next $3 billion 0.650%Next $5 billion 0.625%Over $10 billion 0.600%

For the period ended February 28, 2021, the advisory fee totaled $183,412.

The officers of the Fund are also officers and employees of Barrett AssetManagement and do not receive compensation from the Fund.

3. INVESTMENTS During the period ended February 28, 2021, the aggregate cost of purchases andproceeds from sales of investments (excluding short-term investments) were asfollows:

Purchases Sales__________ _____$344,501 $3,476,394

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4. CAPITAL SHARES At February 28, 2021, the Fund had 15,000,000 shares of capital stock authorizedwith a par value of $0.01 per share. Transactions in shares of the Fund were asfollows:

Period Ended Year EndedFebruary 28, 2021 August 31, 2020________________ _______________

Shares sold 348 663Shares issued on reinvestment 79,848 142,166Shares redeemed (73,932) (217,202)______ _______Net increase (decrease) 6,264 (74,373)______ _____________ _______

5. INCOME TAX The tax character of distributions paid during the fiscal year ended August 31 INFORMATION were as follows:AND 2020 2019DISTRIBUTIONS Distributions paid from:TO Ordinary Income $ 735,348 $ 545,834SHAREHOLDERS Long Term Capital Gain 4,998,326 7,079,166_________ _________

Total Distributions Paid $5,733,674 $7,625,000_________ __________________ _________

The Funds designated as long-term capital gain dividend, pursuant to InternalRevenue Code Section 852(b)(3), to reduce the earnings and profits of the Fundrelated to net capital gain to zero for the tax year ended August 31, 2020.

As of August 31, 2020, the components, inclusive of written call options, ofaccumulated earnings (losses) for income tax purposes were as follows:

Tax cost of Investments $11,842,999__________Unrealized Appreciation 40,902,939Unrealized Depreciation (222,988)__________Net unrealized appreciation (depreciation) 40,679,951Undistributed net investment income —Undistributed long-term gains —__________Distributable earnings —Other accumulated gain/(loss) (24,614)__________Total accumulated gain/(loss) $43,048,760____________________

Additionally, U.S. generally accepted accounting principles require that certaincomponents of net assets relating to permanent differences be reclassifiedbetween financial and tax reporting. These reclassifications have no effect on netassets or net asset value per share. For the year ended August 31, 2020, thefollowing table shows the reclassifications made:

Distributable Earnings Paid In Capital_____________________ ______________$ — $ —

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6. RECENT U.S. and international markets have experienced significant periods of volatility MARKET in recent years due to a number of economic, political and global macro factors EVENTS including the impact of the coronavirus as a global pandemic and related public

health issues, growth concerns in the U.S. and overseas, uncertainties regardinginterest rates, trade tensions and the threat of tariffs imposed by the U.S. andother countries. These developments as well as other events, could result infurther market volatility and negatively affect financial asset prices, the liquidityof certain securities and the normal operations of securities exchanges and othermarkets. As a result, the risk environment remains elevated. The Fund’sinvestment adviser will monitor developments and seek to manage the Fund ina manner consistent with achieving the Fund’s investment objective, but therecan be no assurance that it will be successful in doing so.

7. SUBSEQUENT On March 11, 2021, CI Financial Corp., a diversified global asset and wealth EVENT management company, announced an agreement to acquire Barrett Asset

Management. The closing is expected to occur in the second calendar quarter of2021. It is expected that shareholders of the Fund will be asked to approve anew investment advisory agreement with Barrett Asset Management. Theacquisition is not expected to impact the services to be provided by Barrett AssetManagement to the Fund.

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Additional Information (Unaudited)

1. INFORMATION ABOUT DIRECTORS AND OFFICERS

The business and affairs of the Fund are conducted by management under the supervision and subject tothe direction of its Board of Directors. The business address of each Director is c / o Barrett AssetManagement, LLC, the Fund’s investment manager (“Barrett Asset Management”), 90 Park Avenue,34th Floor, New York, New York, 10016. Information pertaining to the Directors and officers of the Fundis set forth below.

The Statement of Additional Information includes additional information about the Directors and isavailable, without charge, upon request by calling the Fund at 1-877-363-6333.

Number of Portfoliosin Fund Other Board

Position(s) Term of Office* Complex MembershipsName, Address Held with and Length of Principal Occupation(s) Overseen Held by and Birth Year Fund Time Served** During Past 5 Years by Director Director______________ __________ ______________ ______________________ ___________ _____________INDEPENDENT DIRECTORS+:Barry Handel, CPA Director Since 2005 Partner, Shalik, Morris & 1 NoneBirth Year: 1951 Company, LLP

(accounting firm)

David H. Kochman(1) Director Since 2011 Member, Harris Beach 1 NoneBirth Year: 1959 Chairperson Since 2017 PLLC (law firm)

Rosalind A. Kochman(2) Director Since 1990 Retired (since 2002); 1 NoneBirth Year: 1937 formerly, Chief Executive

Officer, Brooklyn EyeSurgery Center, andAdministrator, Kochman,Lebowitz & Mogil, MDs

William Morris, Jr., CPA Director Since 2005 President, William 1 NoneBirth Year: 1948 Morris & Associates P.C.

(accounting firm)(1) Mr. Kochman is Ms. Kochman’s son.(2) Ms. Kochman is Mr. Kochman’s mother.+ Directors who are not “interested persons” of the Fund within the meaning of Section 2(a)(19) of the 1940 Act.

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Number of Portfoliosin Fund Other Board

Position(s) Term of Office* Complex MembershipsName, Address Held with and Length of Principal Occupation(s) Overseen Held by and Birth Year Fund Time Served** During Past 5 Years by Director Director______________ __________ ______________ ______________________ ___________ _____________OFFICERS:Peter H. Shriver, CFA President Since 2006 Chief Executive Officer N/A N/ABarrett Asset Management and Chief of Barrett Asset 90 Park Avenue Executive Management (since 2011);New York, NY 10016 Officer President of Barrett Asset Birth Year: 1952 Management (2011-2014)

E. Wells Beck, CFA Vice Since 2010 Managing Director and N/A N/ABarrett Asset Management President Director of Research, 90 Park Avenue and Barrett Asset Management New York, NY 10016 Investment (since 2011)Birth Year: 1968 Officer

Robert J. Milnamow Vice Since 2014 President and Chief N/A N/ABarrett Asset Management President Investment Officer of 90 Park Avenue and Chief Barrett Asset ManagementNew York, NY 10016 Investment (since 2011); Executive ViceBirth Year: 1950 Officer President, Barrett Asset

Management (2006-2014)

Michael J. Andrews Chief Since 2020 Chief Compliance Officer, N/A N/ABarrett Asset Management Compliance Barrett Asset Management90 Park Avenue Officer (2020-Present); Vice New York, NY 10016 and President & ComplianceBirth Year: 1986 Operations Consulting, Duff & Phelps,

Officer LLC (2019); Deputy Compliance Officer, TimeSquare Capital Management (2015-2019)

John G. Youngman Chief Since 2011 Managing Director, N/A N/ABarrett Asset Management Financial Barrett Asset Management90 Park Avenue Officer (2011-Present)New York, NY 10016 andBirth Year: 1968 Treasurer* Each Director and officer serves until his respective successor has been duly elected and qualified or until his earlier death,

resignation, retirement or removal.** Indicates the earliest year in which the Director became a board member or the officer took such office.

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2. IMPORTANT TAX INFORMATION

For the fiscal year ended August 31, 2020, certain dividends paid by the Funds may be subject to amaximum tax rate of 23.8%, as provided for by the Jobs and Growth Tax Relief Reconciliation Act of2003. The percentage of dividends declared from ordinary income designated as qualified dividendincome was as follows:

Barrett Opportunity Fund 100.00%

For corporate shareholders, the percent of ordinary income distributions qualifying for the corporatedividends received deduction for the fiscal year ended August 31, 2020, was as follows:


The Percentage of taxable ordinary income distributions that are designated as short-term capital gaindistributions under Internal Revenue Section 871(k)(2)(C) for each Fund were as follows (unaudited).


The Fund files its complete schedule of portfolio holdings with the Securities and Exchange Commission(“SEC”) for the first and third quarters of each fiscal year on Form N-PORT Part F. The Fund’s FormsN-PORT Part F are available on the SEC’s website at www.sec.gov. The Fund’s Forms N-PORT Part Fmay be reviewed and copied at the SEC’s Public Reference Room in Washington, D.C., and informationon the operation of the Public Reference Room may be obtained by calling 1-800-SEC-0330. To obtaininformation on Form N-PORT Part F from the Fund, shareholders can call the Fund at 1-877-363-6333.

Information on how the Fund voted proxies relating to portfolio securities during the prior 12-monthperiod ended June 30th of each year and a description of the policies and procedures that the Fund usesto determine how to vote proxies related to portfolio transactions are available (1) without charge, uponrequest, by calling the Fund at 1-877-363-6333 and (2) on the SEC’s website at www.sec.gov.

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BARRETT OPPORTUNITY FUND, INC.c/o U.S. Bank Global Fund Services

615 East Michigan StreetMilwaukee, WI 53202

DIRECTORSBarry Handel, CPA

David H. Kochman, ChairpersonRosalind A. KochmanWilliam Morris, Jr., CPA

INVESTMENT MANAGERBarrett Asset Management, LLC

90 Park AvenueNew York, NY 10016

ADMINISTRATOR, FUND ACCOUNTANT & TRANSFER AGENTU.S. Bank Global Fund Services

615 East Michigan StreetMilwaukee, WI 53202

DISTRIBUTORQuasar Distributors, LLC

111 East Kilbourn Avenue, Suite 2200Milwaukee, WI 53202

CUSTODIANU.S. Bank, N.A.

Custody Operations1555 River Center Drive, Suite 302

Milwaukee, WI 53212

LEGAL COUNSELStradley Ronon Stevens & Young, LLP

2005 Market Street, Suite 2600Philadelphia, PA 19103

INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRMCohen & Company, Ltd.

1350 Euclid Avenue, Suite 800Cleveland, OH 44115

This report is transmitted to the shareholders of Barrett Opportunity Fund, Inc. for their information.This is not a prospectus, circular or representation intended for use in the purchase of shares of the Fundor any securities mentioned in this report.

This report must be preceded or accompanied by a free prospectus. Investors should consider the Fund’sinvestment objective, risks, charges and expenses carefully before investing. The prospectus contains thisand other important information about the Fund. Please read the prospectus carefully before investing.

semi-annual report february 28, 2021

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