0000729218-19-000003.txt : 20190717 0000729218-19-000003.hdr.sgml : 20190717 20190618104457 ACCESSION NUMBER: 0000729218-19-000003 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20190618 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY ADVISOR SERIES II CENTRAL INDEX KEY: 0000795422 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY DIVERSIFIED TRUST DATE OF NAME CHANGE: 19930706 FORMER COMPANY: FORMER CONFORMED NAME: PLYMOUTH FUND DATE OF NAME CHANGE: 19920130 FORMER COMPANY: FORMER CONFORMED NAME: PLYMOUTH INVESTMENT SERIES DATE OF NAME CHANGE: 19911204 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY CONTRAFUND CENTRAL INDEX KEY: 0000024238 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY CONTRAFUND INC DATE OF NAME CHANGE: 19850618 FORMER COMPANY: FORMER CONFORMED NAME: CONTRAFUND INC DATE OF NAME CHANGE: 19810203 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY SALEM STREET TRUST CENTRAL INDEX KEY: 0000035315 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 0430 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY FIXED INCOME TRUST DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY FLEXIBLE BOND FUND DATE OF NAME CHANGE: 19860904 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY CORPORATE BOND FUND INC DATE OF NAME CHANGE: 19851225 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY MUNICIPAL TRUST CENTRAL INDEX KEY: 0000035373 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: MUNICIPAL BOND FUND/MA/ DATE OF NAME CHANGE: 19860327 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY MUNICIPAL BOND FUND INC DATE OF NAME CHANGE: 19850503 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY MUNICIPAL BOND FUND LTD DATE OF NAME CHANGE: 19770201 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY TREND FUND CENTRAL INDEX KEY: 0000035402 IRS NUMBER: 046026956 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY TREND FUND INC DATE OF NAME CHANGE: 19850503 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY CAPITAL TRUST CENTRAL INDEX KEY: 0000275309 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY VALUE FUND DATE OF NAME CHANGE: 19870114 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY DISCOVERER FUND DATE OF NAME CHANGE: 19860803 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY ASSET INVESTMENT TRUST DATE OF NAME CHANGE: 19840205 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Fidelity Newbury Street Trust CENTRAL INDEX KEY: 0000704207 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: NEWBURY STREET TRUST DATE OF NAME CHANGE: 20000630 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY NEWBURY STREET TRUST DATE OF NAME CHANGE: 19970529 FORMER COMPANY: FORMER CONFORMED NAME: DAILY TAX EXEMPT MONEY FUND /DE/ DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY COURT STREET TRUST II CENTRAL INDEX KEY: 0000880709 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY MUNICIPAL TRUST II CENTRAL INDEX KEY: 0000880799 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY DESTINY PORTFOLIOS CENTRAL INDEX KEY: 0000035331 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY DESTINY FUND DATE OF NAME CHANGE: 19860828 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY SYSTEMATIC INVESTMENT FUND INC DATE OF NAME CHANGE: 19690806 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY COURT STREET TRUST CENTRAL INDEX KEY: 0000225323 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY HIGH YIELD MUNICIPALS DATE OF NAME CHANGE: 19870818 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY EXTRA MUNICIPALS DATE OF NAME CHANGE: 19600201 FORMER COMPANY: FORMER CONFORMED NAME: DEVON MUNICIPAL BOND FUND DATE OF NAME CHANGE: 19600201 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY PHILLIPS STREET TRUST CENTRAL INDEX KEY: 0000278001 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY CASH RESERVES DATE OF NAME CHANGE: 19930122 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY HANOVER STREET TRUST CENTRAL INDEX KEY: 0000702533 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY ADVISOR SERIES III DATE OF NAME CHANGE: 19930630 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY FRANKLIN STREET TRUST DATE OF NAME CHANGE: 19920819 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY ADVISOR EQUITY PORTFOLIO INCOME DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY MT VERNON STREET TRUST CENTRAL INDEX KEY: 0000707823 IRS NUMBER: 000000000 FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY GROWTH COMPANY FUND DATE OF NAME CHANGE: 19910110 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY MERCURY FUND DATE OF NAME CHANGE: 19861216 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY FINANCIAL TRUST CENTRAL INDEX KEY: 0000708191 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY FREEDOM FUND DATE OF NAME CHANGE: 19870129 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY TAX QUALIFIED EQUITY FUND DATE OF NAME CHANGE: 19830104 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY ADVISOR SERIES VIII CENTRAL INDEX KEY: 0000729218 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY SPECIAL SITUATIONS FUND DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm Converted by EDGARwiz

 

COMMENTS RECEIVED ON MAY 30, 2019

FROM KENNETH ELLINGTON

FIDELITY ADVISOR SERIES II (File Nos. 033-06516 and 811-04707)

FIDELITY ADVISOR SERIES VIII (File Nos. 002-86711 and 811-03855)

FIDELITY CAPITAL TRUST (File Nos. 002-61760 and 811-02841)

FIDELITY CONTRAFUND (File Nos. 002-25235 and 811-01400)

FIDELITY COURT STREET TRUST (File Nos. 002-58774 and 811-02741)

FIDELITY COURT STREET TRUST II (File Nos. 033-43758 and 811-06453)

FIDELITY DESTINY PORTFOLIOS (File Nos. 002-34099 and 811-01796)

FIDELITY FINANCIAL TRUST (File Nos. 002-79910 and 811-03587)

FIDELITY HANOVER STREET TRUST (File Nos. 002-77571 and 811-03466)

FIDELITY MT VERNON STREET TRUST (File Nos. 002-79755 and 811-03583)

FIDELITY MUNICIPAL TRUST (File Nos. 002-55725 and 811-02628)

FIDELITY MUNICIPAL TRUST II (File Nos. 033-43986 and 811-06454)

FIDELITY NEWBURY STREET TRUST (File Nos. 002-78458 and 811-03518)

FIDELITY PHILLIPS STREET TRUST (File Nos. 002-63350 and 811-02890)

FIDELITY SALEM STREET TRUST (File Nos. 002-41839 and 811-02105)

FIDELITY TREND FUND (File Nos. 002-15063 and 811-00790)



All applicable funds (Form N-CSR Filing)

“Fund Management” (prospectus)


From Fidelity Advisor International Capital Appreciation Fund’s management contract filed on 12/28/2017:


“Performance Adjustment Rate: Except as otherwise provided in sub–paragraph (e) of this paragraph 3, the Performance Adjustment Rate is 0.02% for each percentage point (the performance of the Portfolio and the Index each being calculated to the nearest 0.01%) that the Portfolio’s investment performance for the performance period was better or worse than the record of the Index as then constituted. The maximum performance adjustment rate is 0.20%.”


C:

The Staff requests we include the disclosure above in the Advisory Fees section of the prospectus for all applicable funds.


R:

The “Advisory Fee” section of prospectus was designed to provide a plain English, high-level discussion of the application of the performance adjustment in computing a fund’s management fee. The discussion of the performance adjustment highlights the important fact that the management fee will increase or decrease, depending on the fund’s performance against a specified benchmark index, and also highlights the maximum possible performance adjustment range. Investors that would like additional detail about the operation of the performance adjustment can find this information under the “Computing the Performance Adjustment” in the “Management Contract” section of the applicable fund’s Statement of Additional Information. A fund’s management contract is also publicly available on EDGAR as exhibits to the registration statement. We believe this layered disclosure approach allows investors to access their desired level of detail about a fund’s management fee; accordingly, we have not modified the disclosure.


All applicable funds (Form N-CSR Filing)

“Fund Summary” (prospectus)

“Fee Table”


C:

The Staff requests we include an explanatory footnote in the fee table for all applicable funds that briefly explains the terms of the performance adjustment arrangement: the footnote should disclose a) the fund’s base fee, b) that the base fee may adjust up or down according to fund performance relative to its benchmark index, and c) identify the benchmark index. The Staff states that, for the first year of operations for a new series, the fee table should show the base fee.

R:

The “Fund Management” section of each fund’s statutory prospectus discloses the basic fee (or base rate), describes the operation of the performance adjustment, and identifies the benchmark index. This information is located in the statutory prospectus, and not in the summary prospectus, to address comments previously received from the SEC disclosure staff regarding the content of the fee table and summary prospectus. The management fee line item in the fee table includes a parenthetical designed to inform investors that the fee “fluctuates based on the fund’s performance relative to a securities market index.” Accordingly, we have not modified the applicable funds’ disclosures.