0000912938-17-000164.txt : 20170531 0000912938-17-000164.hdr.sgml : 20170531 20170214121935 ACCESSION NUMBER: 0000912938-17-000164 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20170214 FILER: COMPANY DATA: COMPANY CONFORMED NAME: MFS INSTITUTIONAL MONEY MARKET PORTFOLIO, A SERIES OF THE MFS SERIES TRUST XIV CENTRAL INDEX KEY: 0001392417 IRS NUMBER: 208538605 STATE OF INCORPORATION: MA FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 111 HUNTINGTON AVENUE CITY: BOSTON STATE: MA ZIP: 02199 BUSINESS PHONE: 617-954-5000 MAIL ADDRESS: STREET 1: 111 HUNTINGTON AVENUE CITY: BOSTON STATE: MA ZIP: 02199 FORMER COMPANY: FORMER CONFORMED NAME: MFS Institutional Money Market Portfolio, a series of the MFS Series Trust XIV DATE OF NAME CHANGE: 20090313 FORMER COMPANY: FORMER CONFORMED NAME: MFS Series Trust XIV DATE OF NAME CHANGE: 20070308 CORRESP 1 filename1.htm

MFS® INVESTMENT MANAGEMENT
111 Huntington Avenue, Boston, Massachusetts 02199
Phone 617-954-5000



February 14, 2017


VIA EDGAR (as Correspondence)
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC  20549


RE:
Amendment No. 12 to the Registration Statement on Form N-1A for MFS Series Trust XIV (the "Trust ") on behalf of MFS Institutional Money Market Portfolio (the "Fund") (File No. 811-22033)


Ladies and Gentlemen:

On behalf of the Trust, this letter sets forth our responses to your comments of February 2, 2017, on the above-mentioned amendment filed with the Securities and Exchange Commission (the "SEC") on December 28, 2016 (the "Amendment").

1.  Comment:  With respect to the Fund's fundamental investment restriction number 6, included in "Appendix F – Investment Restrictions" in the Funds' statement of additional information, please confirm that the Fund considers any concentration policy of an underlying fund when monitoring the Fund's industry concentration limit.

Response:
Although we are aware of the SEC Staff's position that a fund should consider any concentration policy of an underlying fund when monitoring the fund's industry concentration limit, MFS is not aware of any formal SEC guidance or legal requirement to do so. Please note that the Fund does not currently invest in underlying funds, but in the remote possibility that it does so in the future, we will consider the legal and disclosure implications of doing so.
 
 
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Securities and Exchange Commission
February 14, 2017
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If you have any questions concerning the foregoing, please call the undersigned at 617-954-5000.


Sincerely,

Susan A. Pereira
Susan A. Pereira
Vice President and Senior Counsel