0000884110-15-000080.txt : 20160107 0000884110-15-000080.hdr.sgml : 20160107 20151026164859 ACCESSION NUMBER: 0000884110-15-000080 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20151026 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Calvert Management Series CENTRAL INDEX KEY: 0000319676 IRS NUMBER: 526211999 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4550 MONTGOMERY AVE STE 1000N CITY: BETHESDA STATE: MD ZIP: 20814 BUSINESS PHONE: 3019514881 MAIL ADDRESS: STREET 1: 4550 MONTGOMERY AVENUE CITY: BETHESDA STATE: MD ZIP: 20814 FORMER COMPANY: FORMER CONFORMED NAME: CALVERT TAX FREE RESERVES DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CALVERT SOCIAL INVESTMENT FUND CENTRAL INDEX KEY: 0000356682 IRS NUMBER: 000000000 FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4550 MONTGOMERY AVE STREET 2: SUITE 1000 N CITY: BETHESDA STATE: MD ZIP: 20814 BUSINESS PHONE: 3019514800 MAIL ADDRESS: STREET 1: CALVERT INVESTMENTS, INC. STREET 2: 4550 MONTGOMERY AVENUE, SUITE 1000 N CITY: BETHESDA STATE: MD ZIP: 20814 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CALVERT FUND CENTRAL INDEX KEY: 0000701039 IRS NUMBER: 526228948 STATE OF INCORPORATION: MD FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4550 MONTGOMERY AVE STREET 2: STE 1000N CITY: BETHESDA STATE: MD ZIP: 02814 BUSINESS PHONE: 3019514881 MAIL ADDRESS: STREET 1: CALVERT INVESTMENTS, INC. STREET 2: 4550 MONTGOMERY AVE., SUITE 1000 N CITY: BETHESDA STATE: MD ZIP: 20814 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CALVERT WORLD VALUES FUND INC CENTRAL INDEX KEY: 0000884110 IRS NUMBER: 521771206 STATE OF INCORPORATION: MD FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4550 MONTGOMERY AVE STREET 2: STE 1000N CITY: BETHESDA STATE: MD ZIP: 20801 BUSINESS PHONE: 3019514881 MAIL ADDRESS: STREET 1: CALVERT INVESTMENTS, INC. STREET 2: 4550 MONTGOMERY AVE SUITE 1000 N CITY: BETHESDA STATE: MD ZIP: 20814 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Calvert Responsible Index Series, Inc. CENTRAL INDEX KEY: 0001105446 IRS NUMBER: 000000000 FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4550 MONTGOMERY AVE STREET 2: STE 1000N CITY: BETHESDA STATE: MD ZIP: 20814 BUSINESS PHONE: 3019514881 MAIL ADDRESS: STREET 1: 4550 MONTGOMERY AVE STREET 2: STE 1000N CITY: BETHESDA STATE: MD ZIP: 20814 FORMER COMPANY: FORMER CONFORMED NAME: CALVERT SOCIAL INDEX SERIES INC DATE OF NAME CHANGE: 20000601 FORMER COMPANY: FORMER CONFORMED NAME: CALVERT 2000 SERIES INC DATE OF NAME CHANGE: 20000207 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CALVERT IMPACT FUND INC CENTRAL INDEX KEY: 0001121624 IRS NUMBER: 000000000 FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4550 MONTGOMERY AVENUE STREET 2: SUITE 1000N CITY: BETHESDA STATE: MD ZIP: 20814 BUSINESS PHONE: 3019514881 MAIL ADDRESS: STREET 1: 4550 MONTGOMERY AVENUE STREET 2: SUITE 1000N CITY: BETHESDA STATE: MD ZIP: 20814 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Calvert SAGE Fund CENTRAL INDEX KEY: 0001438390 IRS NUMBER: 262853921 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4550 MONTGOMERY AVENUE STREET 2: SUITE 1000N CITY: BETHESDA STATE: MD ZIP: 20814 BUSINESS PHONE: 301-951-4881 MAIL ADDRESS: STREET 1: 4550 MONTGOMERY AVENUE STREET 2: SUITE 1000N CITY: BETHESDA STATE: MD ZIP: 20814 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Calvert Variable Products, Inc. CENTRAL INDEX KEY: 0000743773 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4550 MONTGOMERY AVENUE STREET 2: SUITE 1000N CITY: BETHESDA STATE: MD ZIP: 20814 BUSINESS PHONE: 301-951-4800 MAIL ADDRESS: STREET 1: 4550 MONTGOMERY AVENUE STREET 2: SUITE 1000N CITY: BETHESDA STATE: MD ZIP: 20814 FORMER COMPANY: FORMER CONFORMED NAME: SUMMIT MUTUAL FUNDS, INC. DATE OF NAME CHANGE: 20090122 FORMER COMPANY: FORMER CONFORMED NAME: SUMMIT MUTUAL FUNDS INC DATE OF NAME CHANGE: 20000323 FORMER COMPANY: FORMER CONFORMED NAME: CARILLON FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CALVERT VARIABLE SERIES INC CENTRAL INDEX KEY: 0000708950 IRS NUMBER: 000000000 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: C/O CALVERT INVESTMENTS, INC. STREET 2: 4550 MONTGOMERY AVE CITY: BETHESDA STATE: MD ZIP: 20814 BUSINESS PHONE: 301-951-4881 MAIL ADDRESS: STREET 1: O STREET 2: O CITY: O STATE: CA ZIP: 00000 FORMER COMPANY: FORMER CONFORMED NAME: ACACIA CAPITAL CORP DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm CORRESP


Calvert Investments                 Ivy Wafford Duke
Vice President and
Acting General Counsel


October 26, 2015


VIA EDGAR CORRESPONDENCE

U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Attn:     Ms. Lauren Hamilton, Staff Accountant, Division of Investment Management
 
 
Re:
The Calvert Fund
File No. 811-03416

Calvert Impact Fund, Inc.
File no. 811-10045

Calvert Management Series
File No. 811-03101

Calvert SAGE Fund
File No. 811-22212

Calvert Responsible Index Series, Inc.
File No. 811-09877

Calvert Social Investment Fund
File No. 811-03334

Calvert World Values Fund, Inc.
File No. 811-06563


Dear Ms. Hamilton:

This letter is in follow up to our letter of October 15, 2015, responding to oral comments (“Comments”) you provided to Susan Bender and Lance King during a telephone conversation on September 17, 2015, regarding your review of the September 30, 2014 and December 31, 2014 annual report filings on Form N-CSR for the above-referenced registrants (each, a “Company” and collectively, “Calvert”) and other filings including Forms N-Q, N-SAR, 24f-2, etc.)

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1.
Comment: The N-SARs need to be amended to show the city and state of the auditor for the Item 77(b) internal control letter.

Response: Calvert has filed amended N-SARs for September 30 and December 31, 2014, that now include this information.

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Comment: Regarding the Staff’s original comment number 3 for Calvert Long-Term Income Fund: the payable to the advisor is 40% of the total investment advisor expense. If paid monthly, then why is the percentage so high?

Response: The payable to the advisor in Calvert Long Term Income Fund at September 30, 2014 can be primarily attributed to two factors: a significant decrease in assets over the fiscal year and a related late year reduction in expense accruals. While Calvert does not have an expense recapture provision in place, the funds do reverse any excess expense reimbursements paid by the advisor within the fiscal year period. In September 2014, just before fiscal year end, expense accrual true ups resulted in reduced annual gross expenses, which resulted in a larger than normal reverse reimbursement amount payable to the advisor for the one month period of September 2014. Long Term Income’s expenses were greater than the contractual expense cap for the entire 2014 fiscal year. Therefore, shareholders were charged a consistent 1.25% net expense ratio during the entire fiscal year.



On behalf of the Registrant and as an officer of the Registrant, I acknowledge that:

1.    The Registrant is responsible for the adequacy and accuracy of the disclosure in the Form N-CSR and its other filings under the federal securities laws (“Filings”);

2.    Comments of the U.S. Securities and Exchange Commission (the “Commission”) Staff (“Staff”) or changes to disclosure in response to Staff comments on the Filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the Filings; and

3.    The Registrant 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.


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Please call Susan Walker Bender at 301-951-4885 or me if you have any questions or comments.

Sincerely,


/s/ Ivy Wafford Duke
Ivy Wafford Duke

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