Stradley Ronon Stevens & Young, LLP
2000 K Street, N.W., Suite 700
Washington, D.C. 20006
Telephone 202-822-9611
Fax 202-822-0140
www.stradley.com
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Attention:
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Ms. Rebecca Marquigny, Esquire
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Re:
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Nationwide Mutual Funds
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File No. 811-08495
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1.
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Comment: We note that “Portfolio
turnover risk” is listed as a principal risk of the Fund. Please add disclosure about the expectation of high portfolio turnover to the Fund’s Principal Investment Strategies, or kindly alert the Staff where it is presented already.
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2.
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Comment: In the second paragraph under
the Janus Capital Management portion of the Fund’s strategy summary, the disclosure presents a broad range of instruments from which the adviser may build the Fund’s portfolio. However, the strategy summary offers limited guidance about the
actual construction of the portfolio, i.e., how the adviser makes selection decisions based on the stated analytical methods and models. In clear and understandable language, please explain how the manager decides which type of instrument
would be most advantageous in any particular situation. Clarify how she/he applies the models and analysis to make buy and sell decisions. In responding to this comment, please note that principal strategies are those upon which the adviser
will rely – not “may include” – to achieve the Fund’s objective. As such, the description of potential holdings should avoid equivocal language like “may include.”
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3.
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Comment: Under the Janus Capital Management portion of the Fund’s strategy summary, the disclosure states, “Such models include a proprietary options implied information model
that monitors day-to-day movements in options prices for indicators of risk and reward between asset classes and sectors. Using these proprietary models, Janus adjusts the sleeve’s allocations and the security exposures.” Please rewrite
this disclosure in plain English. Specifically, please explain what is a “proprietary options implied information model” and how do options prices provide indicators of risk and reward between asset classes and sectors?
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4.
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Comment: Under the “Lending of Portfolio Securities” section, we note that the Registrant removed “reasonable” from the fourth condition in the second paragraph: “The Fund must
receive [reasonable] interest on the loan, as well as any dividends, interest or other distributions payable on the loaned securities.” Please add “reasonable” back into the disclosure or in your response letter explain the reason for the
change.
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Respectfully submitted,
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/s/Jessica D. Burt
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Jessica D. Burt, Esquire
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cc:
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Allan J. Oster, Esquire
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Prufesh R. Modhera, Esquire
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Peter M. Hong, Esquire
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Jessica L. Patrick, Esquire
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