-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, QH6BOIefkHfalQ4IAyyaZFLskQc/LkIE3gPDxstWX4v/aoJOmJclvyoID/c2JRGs I+1ljb4djPRvy6g5H7YWWA== 0000950136-04-004480.txt : 20050519 0000950136-04-004480.hdr.sgml : 20050519 20041222104608 ACCESSION NUMBER: 0000950136-04-004480 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20041222 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VALUE LINE US GOVERNMENT SECURITIES FUND INC CENTRAL INDEX KEY: 0000352430 IRS NUMBER: 133083943 FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 220 E 42ND ST CITY: NEW YORK STATE: NY ZIP: 10017 BUSINESS PHONE: 2129071500 FORMER COMPANY: FORMER CONFORMED NAME: VALUE LINE BOND FUND INC DATE OF NAME CHANGE: 19860930 CORRESP 1 file001.htm CORRESPONDENCE



                                    BY EDGAR


                                                 December 22, 2004



Mr. Dominic Minore
Division of Investment Management
United States Securities and Exchange Commission
450 Fifth Street NW
Washington, DC 20549

     Re:  Value Line U.S. Government Securities Fund, Inc.
          File Nos. 2-71928; 811-03171

Dear Mr. Minore:

     This letter is in response to the comments that you communicated to me by
telephone on December 13, 2004 regarding the above-named Fund.

          1.   Disclosure of risks in investing in securities issued by Freddie
               Mac and Fannie Mae. We believe that the disclosure on pages 2 and
               8 of the Prospectus are adequate but we have made some minor
               additions.

          2.   Disclosure required by the new instruction to Item 6(a)(1). We
               are adding additional material under the caption "Net Asset
               Value" as follows: "The use of fair value pricing by the Fund may
               cause the NAV to differ from the NAV that would be calculated
               using closing market prices."

          3.   Under the caption "Frequent Purchases and Redemption of Fund
               Shares" we are eliminating references to market timing and are
               adding the following: "The Adviser applies uniformly these
               restrictions in all cases" at the end of the third paragraph. We
               are also revising the second bullet to read: "makes more than
               four exchanges out of the Fund during a calendar year." We are
               also moving the section so that it will appear following "By
               Exchange" on page 14.





          4.   To comply more closely with Items 11(f)(vi) and (vii), we are
               adding under "Disclosure of Portfolio Holdings" in the Statement
               of Additional Information the names of other rating agencies to
               which portfolio holdings information may be distributed. We are
               also revising the penultimate sentence in the third paragraph to
               read as follows: "Except as stated above, unless there are
               legitimate business purposes for selective disclosure and other
               conditions designed to protect the Fund and its shareholders are
               met, the Fund does not provide or permit others to disclose the
               Fund's portfolio holdings to any person." At the end of the last
               paragraph of this section, the following is being added: "and may
               require the Adviser to provide reports on its implementation from
               time to time or require that the Fund's Chief Compliance Officer
               monitor compliance with this policy.

     In connection with this response, the Fund acknowledges that

          A.   The Fund is responsible for the adequacy and accuracy of the
               disclosure in the filings;

          B.   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;
               and

          C.   The Fund 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.

                                                           Very truly yours,



                                                           Peter D. Lowenstein
                                                           Legal Counsel

PDL:psp


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