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Post-Effective
Amendment No. 148 to the Registration Statement Under the Securities Act
of 1933
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Dear
Ms. Stirling:
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Comment:
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Please
ensure that the appropriate legend is included on the cover page of the
summary prospectus indicating that certain documents are incorporated by
reference into the summary
prospectus.
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Response:
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The
following legend will appear on the cover page of the summary
prospectus:
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Comment:
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Please
ensure that the new director disclosure is included in the Funds’
Statement of Additional
Information.
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Response:
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The
new disclosure requirements were included in the 485(a) filing and will
also be reflected in the upcoming 485(b)
filing.
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Summary
Section:
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Comment:
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Please
remove the paragraph under the heading “Fees and
Expenses.”
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Response:
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This
paragraph will be revised to remove the first sentence in its entirety;
however, the remainder of the paragraph will remain as it specifically
describes that each Fund is utilized as a component of various “wrap-fee”
programs sponsored by investment advisers and broker-dealers and that
there are associated fees with participation in such
programs. Importantly, the paragraph further advises the reader
to carefully read the brochure provided in connection with their
participation in the “wrap-fee”
program.
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Comment:
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Please
remove the reference in the Section entitled “Example of Expenses” to
‘reinvesting all distributions’ and further, remove the footnote to the
table that follows that indicates that all fees associated with an
investment in the Fund are being absorbed by the
adviser.
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Response:
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The
text following the section indicated in the comment above, will be changed
to reflect the following:
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‘This
example is intended to help you compare the cost of investing in the Fund
with the cost of investing in other mutual funds. It assumes
that you invest $10,000 in the Fund for the time periods indicated below
and then either redeem all of your shares at the end of the these periods
or continue to hold them; your investment has a 5% return each year, and
the Fund’s operating expenses remain the same, although your actual costs
may be higher or lower.’
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In
addition, the footnote following the expense table, as requested, will be
removed.
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Comment:
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In
the “Principal Investment Strategies” section in the Series G Fund summary
prospectus, please include a reference to the Fund’s ability to invest at
least 60% of the Fund’s net assets in investment grade mortgage-backed
securities issued by the U.S. Government or its agencies, including to be
announced securities; up to 40% of the Fund’s total assets in debt
securities issued by the U.S. Treasury, U.S. Government agencies or
government sponsored entities; and up to 40% of the Fund’s total assets in
non-government investment-grade debt
securities.
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Response:
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The
disclosure has been added as
requested.
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Comment:
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Per
Item 4(b)(2)(i) of N-1A, please revise the first sentence in the section
entitled “Performance” to include a reference to the risks associated with
investment in the Fund.
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Response:
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The
sentence has been revised and now reads as
follows:
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‘The
following provides some indication of the risks of investing in the Fund
by showing changes in the Fund’s performance from year to
year.’
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Comment:
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Please
remove the paragraph appearing under the section entitled “Fund
Management.”
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Response:
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The
disclosure has been removed as
requested.
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Comment:
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Per
Item 6(b) of N-1A, please reference in the section entitled “Summary of
Other Important Information Regarding Purchase and Sale of Fund Shares”
the manner in which Fund shares can be
redeemed.
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Response:
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The
disclosure has been added as
requested.
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Comment:
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Per
Item 8 of N-1A, please include disclosure regarding the Fund making
certain payments to intermediaries for the sale of Fund shares and related
services.
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Response:
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The
Funds do not make such payments and therefore, the disclosure will not be
included.
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Comment:
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In
the “Principal Investment Strategies” section in the Series M Fund summary
prospectus, please include a reference to the Fund’s ability to invest at
least 60% of the Fund’s net assets in municipal securities that pay
interest exempt from federal income tax, but not necessarily the federal
AMT; up to 40% of the Fund’s net assets in municipal securities that pay
interest subject to federal AMT; up to 40% of the Fund’s total assets in
below investment-grade municipal securities; and up to 10% of the Fund’s
net assets in corporate debt
securities.
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Response:
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The
disclosure has been added as
requested.
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Comment:
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In
the “Principal Investment Strategies” section in the Series M Fund summary
prospectus, please delete the sentence that refers to the Fund’s ability
to invest a portion of its net assets in securities that pay interest
subject to federal AMT as it is redundant to disclosure included earlier
in the document.
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Response:
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The
disclosure has been removed as requested in both the summary and statutory
sections of the Series M Fund
prospectus.
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*
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*
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*
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We
also make the following representations to
you:
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·
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The
Funds are responsible for the adequacy and accuracy of the disclosure in
the filings;
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Staff
comments or changes to disclosure in response to staff comments in the
filings reviewed by the staff do not foreclose the Commission from taking
any action with respect to the filing;
and
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·
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The
Funds may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities
laws of the United States.
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