CORRESP 1 filename1.htm Converted by EDGARwiz

COMMENTS RECEIVED ON JULY 28, 2017

FROM EDWARD BARTZ

FIDELITY HASTINGS STREET TRUST (File Nos. 002-11517 and 811-00215)

Fidelity Advisor Series Growth & Income Fund & Fidelity Series Growth & Income Fund

POST-EFFECTIVE AMENDMENT NO. 163


 

Fund Summary (prospectus)

Fee Table

 

[Fidelity Management & Research Company (FMR) has contractually agreed to reimburse the fund to the extent that total operating expenses (excluding interest, certain taxes, certain securities lending costs, brokerage commissions, fees and expenses of the Independent Trustees, proxy and shareholder meeting expenses, extraordinary expenses, and acquired fund fees and expenses, if any), as a percentage of its average net assets, exceed 0.014%. This arrangement will remain in effect through August 31, 2020. FMR may not terminate this arrangement before the expiration date without the approval of the Board of Trustees.]


C:

The Staff requests the fee waivers be filed as an exhibit to the registration statement.


R:

There is no agreement to be filed under Item 28(h). Instead, this particular arrangement is an undertaking made by FMR pursuant to which it is bound in accordance with the disclosure to reimburse certain expenses through the stated date (as compared with a voluntary arrangement, which could be discontinued by FMR at any time).


 

Fund Summary (prospectus)

Principal Investment Strategies


C:

The Staff requests that we disclose the market capitalization policy for each fund. The Staff also requests we add small and mid-cap risks if appropriate.


R:

Each fund does not have a principal investment policy of investing in securities with a particular market capitalization. Similarly, the risks associated with small and mid-cap investing are not principal investment risks of each fund. Accordingly, we have not modified disclosure. Note, however, that while not a principal risk per se, the possibility for market developments to affect different parts of the market (for example, issuers with different market capitalizations) differently is one of the factors addressed under Principal Investment Risks -Stock Market Volatility.


 

Fund Summary (prospectus)

Principal Investment Strategies

 

Investing in domestic and foreign issuers.


C:

The Staff questions whether each fund will invest in emerging markets securities and, if so, asks that we provide appropriate strategy and risk disclosure.


R:

Although each fund may invest in securities of foreign issuers, including emerging markets securities, investments in emerging markets are not a principal investment strategy of each fund. As a result, each fund believes that its current strategy and risk disclosure are appropriate.





Fund Summary (prospectus)

Principal Investment Strategies


C:

The Staff requests that we add growth and value investing risks to Principal Investment Risks in the Fund Summary section.


R:

The risks associated with these specific investment styles are not principal investment risks of the funds. Accordingly, we have not added disclosure. Note, however, that while not a principal risk per se, the possibility for market developments to affect different types of securities (for example, growth stocks vs. value stocks) differently is one of the factors addressed under Principal Investment Risks - - Stock Market Volatility in the Investment Details section.


 

Fund Summary (prospectus)

Principal Investment Risks

 

Issuer-Specific Changes.  The value of an individual security or particular type of security can be more volatile than, and can perform differently from, the market as a whole. Lower-quality debt securities (those of less than investment-grade quality, also referred to as high yield debt securities or junk bonds) and certain types of other securities involve greater risk of default or price changes due to changes in the credit quality of the issuer. The value of lower-quality debt securities and certain types of other securities can be more volatile due to increased sensitivity to adverse issuer, political, regulatory, market, or economic developments.


C:

The Staff requests a separate risk be added specific to junk bonds.


R:

We believe that the risks associated with investing in lower-quality debt securities are described in Issuer-Specific Changes and, therefore, the addition of a separate risk factor for this type of investment would be duplicative.  


 

Investment Details (prospectus)

Principal Investment Strategies

 

In addition to the principal investment strategies discussed above, the Adviser may lend the fund's securities to broker-dealers or other institutions to earn income for the fund.


C:

The Staff requests we move the language above out of the Principal Investment Strategies section since it is not a principal investment strategy.


R:

Although the strategy noted in the disclosure is not a principal investment strategy of the funds, the funds believe that it is appropriate to discuss the strategy in this section of the prospectus. In addition, the funds have clearly disclosed that these strategies are non-principal investment strategies in response to Staff comments provided to other Fidelity mutual funds.