0000878467-16-000934.txt : 20160802 0000878467-16-000934.hdr.sgml : 20160802 20160404105904 ACCESSION NUMBER: 0000878467-16-000934 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20160404 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY UNION STREET TRUST CENTRAL INDEX KEY: 0000035330 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 0831 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 DAILY INCOME TRUST DATE OF NAME CHANGE: 19900626 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 NEW YORK MUNICIPAL TRUST CENTRAL INDEX KEY: 0000718581 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 0131 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 NEW YORK TAX FREE FUND DATE OF NAME CHANGE: 19900625 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY NEW YORK TAX EXEMPT MONEY MARKET TRUST DATE OF NAME CHANGE: 19850710 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 REVERE STREET TRUST CENTRAL INDEX KEY: 0001022695 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 6175637000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Fidelity Commonwealth Trust II CENTRAL INDEX KEY: 0001364923 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0228 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 Rutland Square Trust II CENTRAL INDEX KEY: 0001364924 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0228 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 OXFORD STREET TRUST CENTRAL INDEX KEY: 0000028540 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0731 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: DAILY MONEY FUND/MA/ DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: DEVONSHIRE STREET FUND INC DATE OF NAME CHANGE: 19821213 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY MONEY MARKET TRUST CENTRAL INDEX KEY: 0000276516 IRS NUMBER: 042658398 STATE OF INCORPORATION: DE FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02110 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02110 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY ABERDEEN STREET TRUST CENTRAL INDEX KEY: 0000880195 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0331 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 INSTITUTIONAL INVESTORS TRUST DATE OF NAME CHANGE: 19920811 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY HEREFORD STREET TRUST CENTRAL INDEX KEY: 0000917286 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE 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 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY RUTLAND SQUARE TRUST CENTRAL INDEX KEY: 0001265551 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0228 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 6175637559 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Fidelity Central Investment Portfolios II LLC CENTRAL INDEX KEY: 0001401097 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0930 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 Central Investment Portfolios LLC CENTRAL INDEX KEY: 0001303459 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0930 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 NEW YORK MUNICIPAL TRUST II CENTRAL INDEX KEY: 0000878663 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0131 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 CALIFORNIA MUNICIPAL TRUST II CENTRAL INDEX KEY: 0000878662 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0228 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 Colchester Street Trust CENTRAL INDEX KEY: 0000356173 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0331 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: COLCHESTER STREET TRUST DATE OF NAME CHANGE: 19980324 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY INSTITUTIONAL CASH PORTFOLIOS DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: CASH INVESTMENT FUND DATE OF NAME CHANGE: 19850414 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY BEACON STREET TRUST CENTRAL INDEX KEY: 0000311884 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: FIDELITY TAX EXEMPT MONEY MARKET TRUST DATE OF NAME CHANGE: 19900626 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY TAX EXEMPT MONEY MARKET TRUST FUND DATE OF NAME CHANGE: 19881220 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY BOYLSTON STREET TRUST CENTRAL INDEX KEY: 0000700859 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0331 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 INSTITUTIONAL TAX EXEMPT CASH PORTFOLIOS DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: MONEY ASSET FUND /MA/ DATE OF NAME CHANGE: 19880222 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 CORRESP 1 filename1.htm Converted by EDGARwiz

COMMENTS RECEIVED ON March 10, 2016

FROM EDWARD BARTZ

FIDELITY ABERDEEN STREET TRUST (File Nos. 811-06440 and 033-43529)

FIDELITY BEACON STREET TRUST (File Nos. 811-02933 and 002-64791)

FIDELITY BOYLSTON STREET TRUST (File Nos. 811-03407 and 002-76309)

FIDELITY CALIFORNIA MUNICIPAL TRUST II (File Nos. 811-06397 and 033-42890)

FIDELITY CENTRAL INVESTMENT PORTFOLIOS LLC (File No. 811-21667)

FIDELITY CENTRAL INVESTMENT PORTFOLIOS II LLC (File No. 811-22083)

FIDELITY COLCHESTER STREET TRUST (File Nos. 811-03320 and 002-74808)

FIDELITY COMMONWEALTH TRUST II (File Nos. 811-21990 and 333-139428)

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

FIDELITY HEREFORD STREET TRUST (File Nos. 811-07139 and 033-52577)

FIDELITY MONEY MARKET TRUST (File Nos. 811-02861 and 002-62417)

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

FIDELITY NEW YORK MUNICIPAL TRUST (File Nos. 811-03723 and 002-83295)

FIDELITY NEW YORK MUNICIPAL TRUST II (File Nos. 811-06398 and 033-42943)

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

FIDELITY OXFORD STREET TRUST (File Nos. 811-03480 and 002-77909)

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

FIDELITY REVERE STREET TRUST (File No. 811-07807)

FIDELITY RUTLAND SQUARE TRUST (File Nos. 811-21439 and 333-109560)

FIDELITY RUTLAND SQUARE TRUST II (File Nos. 811-21991 and 333-139427)

FIDELITY UNION STREET TRUST (File Nos. 811-02460 and 002-50318)



(Example from Fidelity Aberdeen Street Trust)

“DETERMINATION OF NET ASSET VALUE AND VALUATION OF PORTFOLIO ASSETS

          Section 9.03. The term “Net Asset Value” of any Series shall mean that amount by which the assets of that Series exceed its liabilities, all as determined by or under the direction of the Trustees. Such value shall be determined separately for each Series and shall be determined on such days and at such times as the Trustees may determine. Such determination shall be made with respect to securities for which market quotations are readily available, at the market value of such securities; and with respect to other securities and assets, at the fair value as determined in good faith by the Trustees; provided, however, that the Trustees, without Shareholder approval, may alter the method of valuing portfolio securities insofar as permitted under the 1940 Act and the rules, regulations and interpretations thereof promulgated or issued by the Commission or insofar as permitted by any Order of the Commission applicable to the Series. The Trustees may delegate any of their powers and duties under this Section 9.03 with respect to valuation of assets and liabilities. The resulting amount, which shall represent the total Net Asset Value of the particular Series, shall be divided by the total number of shares of that Series outstanding at the time and the quotient so obtained shall be the Net Asset Value per Share of that Series. At any time, the Trustees may cause the Net Asset Value per Share last determined to be determined again in similar manner and may fix the time when such redetermined value shall become effective. If, for any reason, the net income of any Series, determined at any time, is a negative amount, the Trustees shall have the power with respect to that Series (i) to offset each Shareholder’s pro rata share of such negative amount from the accrued dividend account of such Shareholder, or (ii) to reduce the number of Outstanding Shares of such Series by reducing the number of Shares in the account of each Shareholder by a pro rata portion of that number of full and fractional Shares which represents the amount of such excess negative net income, or (iii) to cause to be recorded on the books of such Series an asset account in the amount of such negative net income (provided that the same shall thereupon become the property of such Series with respect to such Series and shall not be paid to any Shareholder), which account may be reduced by the amount, of dividends declared thereafter upon the Outstanding Shares of such Series on the day such negative net income is experienced, until such asset account is reduced to zero; (iv) to combine the methods described in clauses (i) and (ii) and (iii) of this sentence; or (v) to take any other action they deem appropriate, in order to cause (or in order to assist in causing) the Net Asset Value per



Share of such Series to remain at a constant amount per Outstanding Share immediately after each such determination and declaration. The Trustees shall also have the power not to declare a dividend out of net income for the purpose of causing the Net Asset Value per Share to be increased. The Trustees shall not be required to adopt, but may at any time adopt, discontinue or amend the practice of maintaining the Net Asset Value per Share of the Series at a constant amount.”



1.

“Declaration of Trust”


C:

The Staff would like to know if any negative yield provisions have been invoked by any of the trusts. If so, the Staff would like us to explain the circumstances in detail.


R:

To the best of each Trust’s information and belief, these provisions have not been invoked to date.


2.

“Declaration of Trust”


C:

The Staff would like us to explain how each option would work both functionally and from an accounting perspective. The Staff also noted that a reverse share split must be executed in compliance with State law and would like us to confirm compliance.


R:

Section 9.03(i) through (v) of the Declaration of Trust sets forth various options that a fund may employ to alter its dividend amount or capital structure if the fund’s net income were negative.  Each Trust understands that this type of provision is relatively common for a business/statutory trust organized under the laws of Delaware or Massachusetts, and that the provision would most likely be invoked under extraordinary situations by a money market fund that uses the amortized cost method and/or penny rounding method of pricing to maintain a stable share price.  At this time, each Trust has not determined how it would implement each of the options set forth in this section, both from an operational and an accounting standpoint.


3.

“Declaration of Trust”


C:

The Staff believes recording an asset on the books of the trust for the purposes of offsetting negative income may not be in accordance with GAAP, so the Staff would like Fidelity explain how this provision is in accordance with GAAP.


R:

The Trust has not determined whether implementing any of the options set forth in Section 9.03(i) through (v) would be consistent with GAAP.


4.

“Declaration of Trust”


C:

The Staff would like an explanation of how shareholders would be notified if any of these provisions are invoked.


R:

The Trust has not determined how shareholders would be notified in any of the provisions set forth in Section 9.03(i) through (v).   


5.

“Declaration of Trust”


C:

The Staff questioned whether these provisions only apply to money market funds or whether they could apply to other funds and under which circumstances.




R:

As a technical matter, this type of provision could apply to any type of investment company; however, each Trust believes that the provision would most likely be invoked by a money market fund that uses the amortized cost method and/or penny rounding method of pricing to maintain a stable share price.  


6.

Tandy Representations

C:

The Staff would like us to affirm the following three statements:

1)

The funds are responsible for the adequacy and accuracy of the disclosure in the filings.

2)

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.

3)

The funds may not assert Staff comments as a defense in any proceeding by the Commission or any other person under the Federal Securities Laws.


R:

We affirm the aforementioned statements.