0000002230-18-000024.txt : 20180620
0000002230-18-000024.hdr.sgml : 20180620
20180517145707
ACCESSION NUMBER: 0000002230-18-000024
CONFORMED SUBMISSION TYPE: CORRESP
PUBLIC DOCUMENT COUNT: 1
FILED AS OF DATE: 20180517
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: ADAMS DIVERSIFIED EQUITY FUND, INC.
CENTRAL INDEX KEY: 0000002230
IRS NUMBER: 134912740
STATE OF INCORPORATION: MD
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 500 EAST PRATT STREET
STREET 2: SUITE 1300
CITY: BALTIMORE
STATE: MD
ZIP: 21202
BUSINESS PHONE: 4107525900
MAIL ADDRESS:
STREET 1: 500 EAST PRATT STREET
STREET 2: SUITE 1300
CITY: BALTIMORE
STATE: MD
ZIP: 21202
FORMER COMPANY:
FORMER CONFORMED NAME: ADAMS DIVERSIFIED EQUITY FUND
DATE OF NAME CHANGE: 20150331
FORMER COMPANY:
FORMER CONFORMED NAME: ADAMS EXPRESS CO
DATE OF NAME CHANGE: 19920703
CORRESP
1
filename1.txt
[ADAMS FUNDS LOGO]
May 17, 2018
Via EDGAR
Ken Ellington, Staff Accountant
Division of Investment Management, Disclosure Review Office
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Adams Diversified Equity Fund, Inc., File No. 811-00248
Adams Natural Resources Fund, Inc., File No. 811-02736
Dear Mr. Ellington:
In a telephone conversation with me on May 9, 2018, you
communicated the Securities and Exchange Commission (the
"Commission") staff's (the "Staff") comments on the most recent
Annual Reports of Adams Diversified Equity Fund, Inc. ("ADX") and
Adams Natural Resources Fund, Inc. ("PEO," and together with ADX,
the "Funds") that were filed with the Commission on February 26,
2018. A summary of the Staff's comments, along with the Funds'
responses, is set forth below.
Comments related to both ADX and PEO:
1. Please confirm whether there were any payables owed to the
Directors at period-end (i.e., 12/31/17). If so, going forward
please disclose such payables separately as liabilities in the
Statement of Assets and Liabilities, as required by Article 6-04
(12) of Regulation S-X.
Response:
Amounts due to directors at 12/31/17 were $122,000 for ADX
and $111,000 for PEO related to distributions payable on
deferred restricted stock units. Going forward, these
amounts will be disclosed separately in the Statement of
Assets and Liabilities.
Ken Ellington, Staff Accountant
May 17, 2018
Page 2
2. In the Statement of Operations, please disclose interest and
other income as separate line items, as required by Article 6-07
(1) of Regulation S-X.
Response:
Since the Funds currently utilize money market funds as their
short-term investment vehicle, interest income is no longer
applicable. The amount reflected in "Interest and Other Income"
in the Statement of Operations for each Fund was all "Other
Income" for the annual period ended December 31, 2017. Going
forward, we will delete the reference to Interest when such
income is not applicable and will present these categories of
income separately if applicable.
Comments related to ADX only:
3. For the Affiliates disclosure in Note 1 to the Financial
Statements, please provide the information in table form within
the Schedule of Investments, as required by Article 12-14 of
Regulation S-X.
Response:
We respectfully submit that we have fully satisfied the
requirements in Article 12-14 of Regulation S-X by making
the required disclosures in the Notes to Financial
Statements on page 9 of the 2017 Annual Report. Our
presentation of this information is consistent with, and
follows guidance provided by the staff of the Division of
Investment Management in its response to question #5 under
the matters pertaining to Regulation S-X in the Investment
Company Reporting Modernization Frequently Asked Questions
(most recently updated April 27, 2018).
The guidance states "The Commission staff understands that
the disclosures required by rule 12-14 relate to investments
that are already presented in the schedule of investments
under rule 12-12 and 12-13 through 12-13D, and, as such and
to preserve the readability of the schedule of investments,
would not object if funds chose to provide the additional
disclosures required by rule 12-14 in the notes to the
financial statements."
We have chosen to follow this guidance and submit that our
approach is compliant with Article 12-14.
4. In the Schedule of Investments, please consider disclosing
the Fund's holdings in closed-end funds as a separate investment
category, in accordance with Article 12-12(2) of Regulation S-X.
Response:
We acknowledge the staff's comment. Since closed-end funds
trade on a stock exchange, unlike mutual funds, we believe
that presenting this holding in the Schedule of Investments
as a common stock and not separately as a closed-end fund is
more relevant to shareholders when presented as such. It is
our largest single holding in the Energy sector and is
properly reflected as part of the list of common stocks in
the Energy sector of the portfolio. Also, we respectfully
direct the Staff's attention to Footnote (c) to the Schedule
of Investments, which further discloses that this holding is
a "[n]on-controlled affiliate, a closed-end sector fund,
registered as an investment company under the Investment
Company Act of 1940."
Ken Ellington, Staff Accountant
May 17, 2018
Page 3
* * * * *
We believe that the foregoing has been responsive to the
Staff's comments. Please call the undersigned at (410) 230-2901
or Janis Kerns at (410) 230-2902 if you wish to discuss this
correspondence further. Thank you for your attention to this
matter.
Very truly yours,
/s/ Lawrence L. Hooper, Jr.
Lawrence L. Hooper, Jr.
Vice President, General
Counsel & Corporate
Secretary
cc: Mark E. Stoeckle, Chief Executive Officer
Brian S. Hook, Chief Financial Officer
Janis F. Kerns, Assistant General Counsel