CORRESP 1 filename1.htm Converted by EDGARwiz

COMMENTS RECEIVED ON 08/22/2018

FROM EDWARD BARTZ

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

Fidelity Series Growth & Income Fund (to be renamed Fidelity Series Large Cap Stock Fund)

POST-EFFECTIVE AMENDMENT NO. 168



1)

Fund Summary (prospectus)

Fee Table


C:

The Staff requests we submit a completed fee table and hypothetical expense table when the information becomes available.


R:

The requested information will be sent to you when it becomes available.



2)

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 and may extend it in its discretion after that date.]


C:

If the reimbursement is subject to recoupment, the Staff requests we disclose the terms of recoupment in the footnote.


R:

The reimbursement described in the footnote is subject to recoupment and we have updated the footnote as follows (new disclosure underlined):  


[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% (the Expense Cap). If at any time during the current fiscal year expenses for the fund fall below the Expense Cap, FMR reserves the right to recoup prior reimbursed expenses up to, but not in excess of, the Expense Cap. 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 and may extend it in its discretion after that date.]



3)

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 and may extend it in its discretion after that date.]


C:

The Staff requests confirmation that the agreement will 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).



4)

Fund Summary (prospectus)

Principal Investment Strategies


Normally investing at least 80% of assets in common stocks of companies with large market capitalizations (which, for purposes of this fund, are those companies with market capitalizations similar to companies in the Russell 1000® Index or the S&P 500® Index).


C:

Since the smallest companies in the Russell 1000 Index are small cap stocks, the Staff requests we add small cap risk disclosure to the Principal Investment Risks section.


R:

The risks associated with small investing are not principal investment risks of the 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.



5)

Fund Summary (prospectus)

Principal Investment Strategies


Investing in domestic and foreign issuers.


C:

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


R:

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



6)

Fund Summary (prospectus)

Principal Investment Risks


Investing in either "growth" stocks or "value" stocks or both.


C:

The Staff requests we add growth and value style 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 fund. 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.



7)

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:

The requested change has been made.



8)

Investment Details (prospectus)

Principal Investment Strategies


C:

The Staff requests we confirm that, if derivatives are included in the calculation of the funds compliance with its 80% policy, they are valued at their market values.


R:

Although we understand that in appropriate circumstances derivatives may qualify for the funds name test, the fund confirms that, at this time, the fund is not expected to count derivatives toward its 80% policy. The fund also confirms that, to the extent that it counts derivatives toward its 80% policy, the fund would value its derivatives positions using their mark to market values.