0001144204-19-043894.txt : 20191007 0001144204-19-043894.hdr.sgml : 20191007 20190909115107 ACCESSION NUMBER: 0001144204-19-043894 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20190909 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Value Line Premier Growth Fund, Inc. CENTRAL INDEX KEY: 0000102767 IRS NUMBER: 000000000 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 BUSINESS PHONE: 212 907-1900 MAIL ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 FORMER COMPANY: FORMER CONFORMED NAME: VALUE LINE SPECIAL SITUATIONS FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VALUE LINE FUNDS VARIABLE TRUST CENTRAL INDEX KEY: 0000819978 IRS NUMBER: 061207013 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 BUSINESS PHONE: 212 907-1900 MAIL ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 FORMER COMPANY: FORMER CONFORMED NAME: VALUE LINE STRATEGIC ASSET MANAGEMENT TRUST DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VALUE LINE TAX EXEMPT FUND INC CENTRAL INDEX KEY: 0000733257 IRS NUMBER: 133187370 FISCAL YEAR END: 0228 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: C/O VALUE LINE INC STREET 2: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 BUSINESS PHONE: 212 907-1900 MAIL ADDRESS: STREET 1: C/O VALUE LINE INC STREET 2: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VALUE LINE CAPITAL APPRECIATION FUND INC CENTRAL INDEX KEY: 0000102757 IRS NUMBER: 136065520 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 BUSINESS PHONE: 212 907-1900 MAIL ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 FORMER COMPANY: FORMER CONFORMED NAME: VALUE LINE INCOME & GROWTH FUND INC DATE OF NAME CHANGE: 19990430 FORMER COMPANY: FORMER CONFORMED NAME: VALUE LINE INCOME FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Value Line Mid Cap Focused Fund, Inc. CENTRAL INDEX KEY: 0000102756 IRS NUMBER: 133139843 STATE OF INCORPORATION: NY FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 BUSINESS PHONE: 212 907-1900 MAIL ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 FORMER COMPANY: FORMER CONFORMED NAME: VALUE LINE FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Value Line Larger Companies Focused Fund, Inc. CENTRAL INDEX KEY: 0000102764 IRS NUMBER: 132696372 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 BUSINESS PHONE: 212 907-1900 MAIL ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 FORMER COMPANY: FORMER CONFORMED NAME: VALUE LINE LARGER COMPANIES FUND, INC. DATE OF NAME CHANGE: 20060602 FORMER COMPANY: FORMER CONFORMED NAME: VALUE LINE LEVERAGED GROWTH INVESTORS INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: VALUE LINE LEVERAGED GROWTH FUND INC DATE OF NAME CHANGE: 19730906 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Value Line Core Bond Fund CENTRAL INDEX KEY: 0000783316 IRS NUMBER: 136866048 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 BUSINESS PHONE: 212-907-1900 MAIL ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 FORMER COMPANY: FORMER CONFORMED NAME: VALUE LINE AGGRESSIVE INCOME TRUST DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VALUE LINE CENTURION FUND INC CENTRAL INDEX KEY: 0000726994 IRS NUMBER: 000000000 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 BUSINESS PHONE: 2129071900 MAIL ADDRESS: STREET 1: 7 TIMES SQUARE CITY: NEW YORK STATE: NY ZIP: 10036 CORRESP 1 filename1.htm

  

Value Line Funds

7 Times Square, Suite 1606

New York, New York 10036-6524

 

September 9, 2019

 

Via Edgar Correspondence

Mr. David Manion

Securities and Exchange Commission

Division of Investment Management

Disclosure Review and Accounting Office

100 F Street, N.E.

Washington, D.C. 20549

 

Maniond@SEC.gov

 

Re: Value Line Mutual Funds

 

Dear Mr. Manion:

 

This letter responds to comments of the staff of the Securities and Exchange Commission (the “Commission”) transmitted orally to Peter Lowenstein, Emily Washington, Michael Wagner and Anthony Frazia on September 3, 2019, relating to the N-CSR and N-CEN filings of certain Value Line Mutual Funds (the “Funds”) for the fiscal year ended December 31, 2018.

 

For the staff’s convenience, its comments are restated below followed by the response of the Funds.

 

Comment 1.

 

The Funds filed an amended Certified Shareholders Report Form N-CSR on March 25, 2019, to include the signature of PricewaterhouseCoopers, LLP, the Funds’ Independent Registered Public Accounting Firm. Please confirm that no other changes were made.

 

Response 1.

 

Confirmed.

 

Comment 2.

 

In the future, please include an explanatory note in any amended filing noting the changes being made.

  

Response 2.

 

An explanatory note will be included in any future amended filing noting the changes being made.

 

 

 

 

Page 2

 

 

Comment 3.

 

The officers’ certifications that were included in the Amended Reports filed on March 25, 2019, were out of date. Please file another amendment to include updated certifications with an explanatory note that no other changes are being made.

 

Response 3.

 

Amendments were filed on September 4, 2019, with an appropriate explanatory note.

 

Comment 4.

 

The auditor’s internal control report needs to be filed with the Funds’ Annual Reports on Form N-CEN.

 

Response 4.

 

Amendments to Form N-CEN including the auditor’s internal control report were filed on September 6,2019, with an appropriate explanatory note.

 

*******************

 

We trust that these responses adequately address your comments.

 

Should you have any further questions or comments, please do not hesitate to contact me at (212) 907-1850.

 

Very truly yours,

 

/s/ Peter D. Lowenstein

 

Legal Counsel to the Value Line Mutual Funds

 

 

cc:Leonard A. Pierce, Esq.

Gretchen Passe Roin, Esq.