1900 K Street, NW | |
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COREY F. ROSE |
February 13, 2017
VIA EDGAR CORRESPONDENCE
Deborah ONeal-Johnson
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549-4644
Re: The Hartford Mutual Funds, Inc. (the Registrant) (SEC File Nos. 333-02381 and 811-07589)
Dear Ms. ONeal-Johnson:
We are writing in response to comments you provided telephonically to Alice Pellegrino, Amber Kopp and me on November 16, 2016 with respect to the Registrants Post-Effective Amendment No. 148 filed on September 26, 2016, relating to the Hartford Global Impact Fund (the Fund). On behalf of the Fund, we have reproduced your comments below and provided the Funds responses immediately thereafter. Capitalized terms have the meanings attributed to such terms in the Post-Effective Amendment.
1. |
Comment: |
Please provide supplementally a completed Annual Fund Operating Expenses table for the Fund. |
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Response: |
The Annual Fund Operating Expenses table for the Fund is attached as Appendix I. |
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2. |
Comment: |
With respect to the expense reimbursement arrangements disclosed in the footnote to the Funds Annual Operating Expenses table, please discuss whether the amounts reimbursed pursuant to these arrangements can be recouped by the reimbursing party. |
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Response: |
Amounts reimbursed under the expense reimbursement arrangements described in the footnote to the Funds Annual Fund Operating Expenses table may not be recouped by the reimbursing party. |
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3. |
Comment: |
Please provide supplementally a completed Expense Example for the Fund. |
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Response: |
The Expense Example for the Fund is attached as Appendix II. |
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4. |
Comment: |
Does the Fund rely on any specific quantitative criteria in determining its areas of investment? |
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Response: |
The Fund seeks to invest its assets in companies that focus their operations in areas that the portfolio managers believe are likely to address major social and environmental challenges including, but not limited to, hunger, health, clean water and sanitation, affordable housing, education and training, financial inclusion, narrowing the digital divide, alternative energy, resource stewardship and resource efficiency. There are no specific quantitative criteria guiding the Funds investments in such areas. |
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Additionally, the Registrants criteria used to determine the companies in which the Fund may invest are: 1) a companys core business and majority of operating activity must align with the impact themes listed in the Principal Investment Strategy; 2) the social impact goals that the company addresses cannot by easily met by other means; and 3) companys social impact must be measurable. |
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5. |
Comment: |
Please confirm that all types of derivatives in which the Fund may principally invest are disclosed in the Principal Investment Strategy section. |
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Response: |
The Registrant confirms that the Fund does not invest in derivatives as a principal strategy. |
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6. |
Comment: |
With respect to the Funds Annual Fund Operating Expenses table, to the extent acquired fund fees and expenses exceed 1 basis point of the Funds average net assets, please include a line item in the expense table for Acquired fund fees and expenses. |
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Response: |
As acquired fund fees and expenses are not expected to exceed 1 basis point of the Funds average net assets during the fiscal year, the Registrant has not included a line item for Acquired fund fees and expenses in the Funds expense table. |
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7. |
Comment: |
Please confirm supplementally that the Fund will not invest more than 15% of its assets in illiquid securities |
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Response: |
The Registrant confirms that the Fund may not invest more than 15% of the Funds net assets in illiquid securities pursuant to the Non-Fundamental Investment Restrictions of the Fund as disclosed in the SAI. |
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8. |
Comment: |
With respect to the Related Composite Performance section of the Funds Prospectus, please confirm whether the composite consists of all accounts or only fee paying accounts. |
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Response: |
The Registrant confirms that all accounts were included in the Related Composite Performance section. |
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9. |
Comment: |
Please confirm that the Funds related composite performance is net of all fees and expenses, not just the management fee. |
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Response: |
The Registrant confirms that the Funds related composite performance is net of all fees and expenses. |
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10. |
Comment: |
Please confirm that the investment adviser or sub-adviser has the supporting data for the calculation of the related composite performance for the Fund as required by Rule 204-2(a)(16) under the Investment Advisers Act of 1940. |
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Response: |
The Registrant confirms that the sub-adviser has the supporting data for the calculation of the related composite performance for the Fund as required by Rule 204-2(a)(16) under the Investment Advisers Act of 1940, as amended. |
Should you have any questions, please feel free to contact me at (202) 261-3314.
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Sincerely, |
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/s/ Corey F. Rose |
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Corey F. Rose |
cc: Alice A. Pellegrino
John V. OHanlon
Appendix I
ANNUAL FUND OPERATING EXPENSES
(expenses that you pay each year as a percentage of the value of your investment)
Share |
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A |
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T |
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C |
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I |
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R3 |
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R4 |
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R5 |
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R6 |
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Y |
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F |
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Management fees(1) |
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0.75 |
% |
0.75 |
% |
0.75 |
% |
0.75 |
% |
0.75 |
% |
0.75 |
% |
0.75 |
% |
0.75 |
% |
0.75 |
% |
0.75 |
% |
Distribution and service (12b-1) fees |
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0.25 |
% |
0.25 |
% |
1.00 |
% |
None |
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0.50 |
% |
0.25 |
% |
None |
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None |
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None |
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None |
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Total other expenses |
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0.74 |
% |
0.74 |
% |
0.74 |
% |
0.64 |
% |
0.71 |
% |
0.66 |
% |
0.61 |
% |
0.50 |
% |
0.55 |
% |
0.50 |
% |
Administrative services fee |
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None |
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None |
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None |
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None |
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0.20 |
% |
0.15 |
% |
0.10 |
% |
None |
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None |
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None |
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Other expenses(1) |
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0.74 |
% |
0.74 |
% |
0.74 |
% |
0.64 |
% |
0.51 |
% |
0.51 |
% |
0.51 |
% |
0.50 |
% |
0.55 |
% |
0.50 |
% |
Total annual fund operating expenses |
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1.74 |
% |
1.74 |
% |
2.49 |
% |
1.39 |
% |
1.96 |
% |
1.66 |
% |
1.36 |
% |
1.25 |
% |
1.30 |
% |
1.25 |
% |
Fee waiver and/or expense reimbursement(2) |
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0.49 |
% |
0.49 |
% |
0.49 |
% |
0.39 |
% |
0.41 |
% |
0.41 |
% |
0.41 |
% |
0.40 |
% |
0.40 |
% |
0.40 |
% |
Total annual fund operating expenses after fee waiver and/or expense reimbursement(2) |
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1.25 |
% |
1.25 |
% |
2.00 |
% |
1.00 |
% |
1.55 |
% |
1.25 |
% |
0.95 |
% |
0.85 |
% |
0.90 |
% |
0.85 |
% |
(1) Fees and expenses are based on estimated amounts for the current fiscal year. The amount shown under Management fees includes the management fee of the Master Portfolio (as defined below). The fee table and the example reflect the expenses of both the Fund and the Master Portfolio in which the Fund invests.
(2) Hartford Funds Management Company, LLC (the Investment Manager) has contractually agreed to reimburse expenses (exclusive of taxes, interest expenses, brokerage commissions, acquired fund fees and expenses and extraordinary expenses) to the extent necessary to maintain total annual fund operating expenses as follows: 1.25% (Class A), 1.25% (Class T), 2.00% (Class C), 1.00% (Class I), 1.55% (Class R3), 1.25% (Class R4), 0.95% (Class R5), 0.85% (Class R6), 0.90% (Class Y) and 0.85% (Class F). In addition, Hartford Administrative Services Company (HASCO), the Funds transfer agent, has contractually agreed to reimburse any portion of the transfer agency fees over 0.30% of the average daily net assets per fiscal year for Class A, T, C, I, R3, R4, R5 and Y shares. Each contractual arrangement will remain in effect until February 28, 2018 and shall renew automatically for one-year terms thereafter unless the Investment Manager or HASCO, respectively, provides written notice of termination prior to the start of the next term or upon approval of the Board of Directors of The Hartford Mutual Funds, Inc. HASCO has contractually agreed to reimburse all transfer agency fees for Class R6 and F Shares until February 28, 2018.
Appendix II
EXAMPLE. The examples below are intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The examples assume that:
· Your investment has a 5% return each year
· The Funds operating expenses remain the same (except that the examples reflect the expense limitation arrangements for only the first year)
· You reinvest all dividends and distributions
· You pay any deferred sales charge due for the applicable period.
Your actual costs may be higher or lower. Based on these assumptions, for every $10,000 invested, you would pay the following expenses if you sell all of your shares at the end of each time period indicated:
Share Classes |
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Year 1 |
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Year 3 |
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A |
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$ |
670 |
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$ |
1,023 |
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T |
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$ |
374 |
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$ |
738 |
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C |
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$ |
303 |
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$ |
729 |
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I |
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$ |
102 |
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$ |
402 |
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R3 |
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$ |
158 |
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$ |
576 |
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R4 |
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$ |
127 |
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$ |
483 |
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R5 |
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$ |
97 |
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$ |
390 |
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R6 |
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$ |
87 |
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$ |
357 |
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Y |
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$ |
92 |
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$ |
373 |
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F |
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$ |
87 |
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$ |
357 |
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You would pay the following expenses if you did not redeem your shares:
Share Classes |
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Year 1 |
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Year 3 |
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A |
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$ |
670 |
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$ |
1,023 |
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T |
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$ |
374 |
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$ |
738 |
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C |
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$ |
203 |
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$ |
729 |
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I |
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$ |
102 |
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$ |
402 |
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R3 |
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$ |
158 |
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$ |
576 |
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R4 |
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$ |
127 |
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$ |
483 |
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R5 |
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$ |
97 |
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$ |
390 |
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R6 |
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$ |
87 |
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$ |
357 |
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Y |
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$ |
92 |
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$ |
373 |
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F |
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$ |
87 |
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$ |
357 |
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