Re:
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The Purisima Funds (the “Trust”)
File Nos.: 333-09153 and 811-07737
The Purisima Total Return Fund (S000005935)
The Purisima All-Purpose Fund (S000005936)
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1.
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The Trust acknowledges that in connection with the comments made by the Staff of the SEC, the Staff has not passed generally on the accuracy or adequacy of the disclosure made herein, and the Funds and their management are responsible for the content of such disclosure;
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2.
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The Trust acknowledges that the Staff’s comments and changes in disclosure in response to the Staff’s comments does not foreclose the Commission or other regulatory agencies from the opportunity to seek enforcement or take other action with respect to the disclosure made herein; and
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3.
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The Trust represents that neither the Funds nor their management will assert the Staff’s comments or changes in disclosure in response to the Staff’s comments as a defense in any action or proceeding by the SEC or any person under the federal securities laws of the United States.
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1.
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Staff Comment: The dollar amount in “Growth of …” example as reflected in Form N-CSR for the Purisima Total Return Fund and Purisima All-Purpose Fund should reflect the minimum investment amount of $25,000. This change should be made in the next filing.
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2.
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Staff Comment: In “Note 1 – Organization” in the “Notes to Financial Statements” section beginning on Page 18 for the Purisima Total Return Fund, state whether the Funds are diversified or non-diversified. This should be updated in the next filing.
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3.
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Staff Comment: In “Note 2 – Significant Accounting Policies” in item “H.” on page 20, include an explanation as to the reason for the reclassification. This should be updated in the next filing.
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4.
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Staff Comment: In “Note 3 – Commitments, Other Related Party Transactions and Other Service Providers” on page 21, in the second paragraph state “Any acquired fund fees would be excluded.” This should be updated in the next filing.
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5.
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Staff Comment: With respect to “Note 3 – Commitments, Other Related Party Transactions and Other Service Providers” on page 21, confirm that the ability to recoup expenses up to the expense limitation means the expense limitation in place at the time and add language to the third paragraph accordingly. This should be updated in the next filing.
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6.
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Staff Comment: On page 23 in the description of the fair value hierarchy, because Level 2 securities are held include a more detailed description/breakdown of the securities (i.e., break out the securities by country). This should be updated in the next filing.
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7.
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Staff Comment: With respect to “Other accumulated loss” in the “components of distributable earnings” breakdown on page 23, the following page discloses post-October capital losses but does not include capital loss carry forwards or range of expiration dates. Confirm whether there are there capital loss carry forwards and disclose the same along with range of expiration dates.
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1.
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Staff Comment: With respect to the Fund’s Schedule of Investments, indicate the fee associated with the Fund’s investment in the SEI Daily Income Trust Government Fund. Such disclosure can be made in the Fund’s prospectus.
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2.
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Staff Comment: In “Item 4”, include a more specific definition of “tax services” describing the nature of the services, and not simply the standard language from Form N-CSR. This change should be made in the next filing.
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