0000930413-16-005998.txt : 20160411 0000930413-16-005998.hdr.sgml : 20160411 20160311141705 ACCESSION NUMBER: 0000930413-16-005998 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20160311 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LORD ABBETT US GOV & GOV SPONSORED ENTERPR MONEY MARKET FUND CENTRAL INDEX KEY: 0000311635 IRS NUMBER: 132986729 STATE OF INCORPORATION: MD FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 90 HUDSON STREET STREET 2: 11TH FLOOR CITY: JERSEY CITY STATE: NJ ZIP: 07302 BUSINESS PHONE: 201-827-2000 MAIL ADDRESS: STREET 1: 90 HUDSON STREET STREET 2: 11TH FLOOR CITY: JERSEY CITY STATE: NJ ZIP: 07302 FORMER COMPANY: FORMER CONFORMED NAME: LORD ABBETT U S GOVERNMENT SECURITIES MONEY MARKET FUND INC DATE OF NAME CHANGE: 19970312 FORMER COMPANY: FORMER CONFORMED NAME: LORD ABBETT CASH RESERVE FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LORD ABBETT MID CAP STOCK FUND INC CENTRAL INDEX KEY: 0000716788 IRS NUMBER: 133166900 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 90 HUDSON STREET STREET 2: 11TH FLOOR CITY: JERSEY CITY STATE: NJ ZIP: 07302 BUSINESS PHONE: 201-827-2000 MAIL ADDRESS: STREET 1: 90 HUDSON STREET CITY: JERSEY CITY STATE: NJ ZIP: 07302 FORMER COMPANY: FORMER CONFORMED NAME: LORD ABBETT MID CAP VALUE FUND INC DATE OF NAME CHANGE: 19960315 FORMER COMPANY: FORMER CONFORMED NAME: LORD ABBOTT MID CAP VALUE FUND INC DATE OF NAME CHANGE: 19960315 FORMER COMPANY: FORMER CONFORMED NAME: LORD ABBETT VALUE APPRECIATION FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LORD ABBETT MUNICIPAL INCOME FUND INC CENTRAL INDEX KEY: 0000737800 IRS NUMBER: 133200760 STATE OF INCORPORATION: MD FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 90 HUDSON STREET STREET 2: 11TH FLOOR CITY: JERSEY CITY STATE: NJ ZIP: 07302 BUSINESS PHONE: 201-827-2000 MAIL ADDRESS: STREET 1: 90 HUDSON STREET STREET 2: 11TH FLOOR CITY: JERSEY CITY STATE: NJ ZIP: 07302 FORMER COMPANY: FORMER CONFORMED NAME: LORD ABBETT TAX FREE INCOME FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LORD ABBETT GLOBAL FUND INC CENTRAL INDEX KEY: 0000829901 IRS NUMBER: 133460109 STATE OF INCORPORATION: NY FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 90 HUDSON STREET CITY: JERSEY CITY STATE: NJ ZIP: 07302 BUSINESS PHONE: 201-827-2000 MAIL ADDRESS: STREET 1: 90 HUDSON STREET CITY: JERSEY CITY STATE: NJ ZIP: 07302 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LORD ABBETT RESEARCH FUND INC CENTRAL INDEX KEY: 0000887194 IRS NUMBER: 136995863 STATE OF INCORPORATION: MD FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 90 HUDSON STREET STREET 2: 11TH FLOOR CITY: JERSEY CITY STATE: NJ ZIP: 07302 BUSINESS PHONE: 201-827-2000 MAIL ADDRESS: STREET 1: 90 HUDSON STREET STREET 2: 11TH FLOOR CITY: JERSEY CITY STATE: NJ ZIP: 07302 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LORD ABBETT INVESTMENT TRUST CENTRAL INDEX KEY: 0000911507 IRS NUMBER: 133731507 STATE OF INCORPORATION: DE FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 90 HUDSON STREET CITY: JERSEY CITY STATE: NJ ZIP: 07302 BUSINESS PHONE: 201-827-2000 MAIL ADDRESS: STREET 1: 90 HUDSON STREET CITY: JERSEY CITY STATE: NJ ZIP: 07302 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LORD ABBETT EQUITY TRUST CENTRAL INDEX KEY: 0001139819 IRS NUMBER: 223805271 FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 90 HUDSON STREET STREET 2: 11TH FLOOR CITY: JERSEY CITY STATE: NJ ZIP: 07301-3973 BUSINESS PHONE: 201-827-2000 MAIL ADDRESS: STREET 1: 90 HUDSON STREET STREET 2: 11TH FLOOR CITY: JERSEY CITY STATE: NJ ZIP: 07302-3973 FORMER COMPANY: FORMER CONFORMED NAME: LORD ABBETT BLEND TRUST DATE OF NAME CHANGE: 20010502 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LORD ABBETT BOND DEBENTURE FUND INC CENTRAL INDEX KEY: 0000060365 IRS NUMBER: 132669319 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 90 HUDSON STREET CITY: JERSEY CITY STATE: NJ ZIP: 07302 BUSINESS PHONE: 201-827-2000 MAIL ADDRESS: STREET 1: 90 HUDSON STREET CITY: JERSEY CITY STATE: NJ ZIP: 07302 FORMER COMPANY: FORMER CONFORMED NAME: LORD ABBETT BOND FUND INC DATE OF NAME CHANGE: 19790412 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LORD ABBETT AFFILIATED FUND INC CENTRAL INDEX KEY: 0000002691 IRS NUMBER: 136020600 STATE OF INCORPORATION: MD FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 90 HUDSON STREET CITY: JERSEY CITY STATE: NJ ZIP: 07302 BUSINESS PHONE: 201-827-2000 MAIL ADDRESS: STREET 1: 90 HUDSON STREET CITY: JERSEY CITY STATE: NJ ZIP: 07302 FORMER COMPANY: FORMER CONFORMED NAME: LORD ABBOTT AFFILIATED FUND INC DATE OF NAME CHANGE: 19960315 FORMER COMPANY: FORMER CONFORMED NAME: AFFILIATED FUND INC DATE OF NAME CHANGE: 19941207 FORMER COMPANY: FORMER CONFORMED NAME: AFFILIATED INC DATE OF NAME CHANGE: 19920721 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LORD ABBETT SERIES FUND INC CENTRAL INDEX KEY: 0000855396 IRS NUMBER: 133536969 STATE OF INCORPORATION: NY FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 90 HUDSON STREET STREET 2: 11TH FLOOR CITY: JERSEY CITY STATE: NJ ZIP: 07302 BUSINESS PHONE: 201-827-2000 MAIL ADDRESS: STREET 1: 90 HUDSON STREET STREET 2: 11TH FLOOR CITY: JERSEY CITY STATE: NJ ZIP: 07302 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LORD ABBETT DEVELOPING GROWTH FUND, INC. CENTRAL INDEX KEY: 0000276914 IRS NUMBER: 132958970 STATE OF INCORPORATION: MD FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 90 HUDSON ST. CITY: JERSEY CITY STATE: NJ ZIP: 07302 BUSINESS PHONE: 201-827-2000 MAIL ADDRESS: STREET 1: 90 HUDSON ST. CITY: JERSEY CITY STATE: NJ ZIP: 07302 FORMER COMPANY: FORMER CONFORMED NAME: LORD ABBETT DEVELOPING GROWTH FUND INC /NEW/ DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: DEVELOPING GROWTH SHARES INC DATE OF NAME CHANGE: 19600201 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LORD ABBETT SECURITIES TRUST CENTRAL INDEX KEY: 0000898031 IRS NUMBER: 133712440 STATE OF INCORPORATION: DE FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 90 HUDSON STREET STREET 2: 11TH FLOOR CITY: JERSEY CITY STATE: NJ ZIP: 07302 BUSINESS PHONE: 201-827-2000 MAIL ADDRESS: STREET 1: 90 HUDSON STREET STREET 2: 11TH FLOOR CITY: JERSEY CITY STATE: NJ ZIP: 07302 CORRESP 1 filename1.htm

LORD ABBETT FAMILY OF FUNDS

90 Hudson Street

Jersey City, NJ 07302

March 7, 2016

Mr. Jason P. Fox

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, DC 20549

Re:	Form N-CSR Review for Various Lord Abbett Funds

Dear Mr. Fox:

This letter responds to comments you provided me during a conference call on February 2, 2016, with respect to your review of various Lord Abbett Funds’ Annual Reports to Shareholders on Form N-CSR (the “Annual Reports”). Your comments related to certain disclosures contained within the Annual Reports are discussed below.

The U.S. Securities and Exchange Commission is referred to herein as the “Commission.” Other capitalized terms used but not defined herein have the meanings given to them in the Annual Reports.

Comment: To the extent that a Fund purchases and sells securities from and to other Lord Abbett Funds or client accounts (i.e., a “cross trade”) pursuant to Rule 17a-7 under the Investment Company Act of 1940, as amended, the Fund must disclose the total purchases, total sales and net realized gain or loss related to its cross trades, as a related party transaction in the Notes to Financial Statements.

Response: Lord Abbett has included the requested disclosure in applicable Fund financial statements commencing with the December 31, 2015 Annual Reports.

Comment: In a Fund’s Management Discussion of Fund Performance (“MDFP”), please include a discussion related to industry or sector concentration if such concentration has a material impact on the Fund’s performance.

Response: Lord Abbett will begin to include a discussion of industry or sector risk in a Fund’s MDFP should an industry or sector concentration have a material impact on the Fund’s performance.

Comment: In a Fund’s MDFP, please include discussion related to the performance of derivatives if such derivatives have a material impact on the Fund’s performance.

Response: Lord Abbett will begin to include a discussion of derivatives exposure in a Fund’s MDFP should the performance of derivatives have a material impact to the Fund’s performance.

Mr. Jason Fox

March 7, 2016

Page 2

Comment: In a Fund’s Schedule of Investments, please define the Referenced Index for Credit Default Swaps on Indexes.

Response: The description of the Referenced Index has previously been included in the Significant Accounting Policies within the Notes to Financial Statements. Commencing with the December 31, 2015 Annual Reports, Lord Abbett will include a description of the Referenced Index for Credit Default Swaps on Indexes in the Schedule of Investments along with a reference to the relevant note in the Notes to Financial Statements.

***

We trust that this correspondence is responsive to your inquiry. In addition, the Registrant acknowledges in connection with this filing the following: (i) it is responsible for the adequacy and accuracy of the disclosure in the filing; (ii) Commission staff comments or changes to the disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and (iii) it 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.

If you have any questions, please call me at (201) 827-2377.

Sincerely,

/s/ Bernard J. Grzelak

Bernard J. Grzelak

Treasurer, Lord Abbett Family of Funds