0000039473-10-000002.txt : 20110715 0000039473-10-000002.hdr.sgml : 20110715 20100223142451 ACCESSION NUMBER: 0000039473-10-000002 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20100223 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FUNDAMENTAL INVESTORS INC CENTRAL INDEX KEY: 0000039473 IRS NUMBER: 221557722 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE MARKET - STEUART TOWER STREET 2: SUITE 1800 CITY: SAN FRANCISCO STATE: CA ZIP: 94105 BUSINESS PHONE: 415-421-9360 MAIL ADDRESS: STREET 1: P.O. BOX 7650 (MICG) CITY: SAN FRANCISCO STATE: CA ZIP: 94120 FORMER COMPANY: FORMER CONFORMED NAME: FUNDAMENTAL INVESTORS INC DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm ficorr.htm
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Fundamental Investors
One Market
Steuart Tower, Suite 1800
San Francisco, California 94105
415/421-9360

Patrick F. Quan
Secretary


February 23, 2010


Ms. Laura Hatch, Staff Accountant
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549


Re:
Fundamental Investors
 
File Nos. 811-00032 and 002-10760


Dear Ms. Hatch:

This letter is in response to oral comments we received from you on January 27, 2010 to the fund’s Post-Effective Amendment No. 98 to the Registration Statement under the Securities Act of 1933 and Amendment No. 41 to the Registration Statement under the Investment Company Act of 1940.  We appreciate your prompt response to the filing.

Our responses to your comments are set forth below. We will incorporate any changes to the fund’s Registration Statement in a filing pursuant to Rule 485(b) to be automatically effective on March 1, 2010.

1.           Fees and Expenses, Example – page 2 of the fund’s prospectus

Comment:  Please remove the following language in the paragraph preceding the table: “that you pay the maximum initial or contingent deferred sales charge.”  This disclosure is not permitted by Form N-1A.

Response:   We have updated our disclosure in response to this comment.

2.           Principal investment strategies – page 3 of the fund’s prospectus

Comment:  Please provide more detail in this section about the types of securities in which the fund invests.  For example, please explain how the fund achieves the income portion of its objective.

Response:   We have updated the disclosure in response to this comment.

3.           Principal investment strategies – page 3 of the fund’s prospectus

Comment:  If the investing in securities rated below investment grade is a principal investment strategy of the fund, please explain this in the principal investment strategies section and include a description of credit risk in the principal risks section.

Response:  Because investing in securities rated below investment grade is not currently a principal investment strategy of the fund, we have not included this in the principal investment strategies section nor in the principal risks section.

4.           Principal investment strategies – page 3 of the fund’s prospectus

Comment: If investing in securities in developing countries is a principal investment strategy of the fund, please include this in the principal investment strategies section.

Response:  Because investing in securities in developing countries is not currently a principal investment strategy of the fund, we have not included this in the principal investment strategies section.

5.           Investment Results – page 5 of the fund’s prospectus

Comment: Please remove the second footnote from the table.

Response: Thank you for discussing this comment with us further over the phone.  Because we are showing lifetime results in the investment results table for a fund which was previously managed by another investment adviser, we appreciate the Staff’s interpretation that we can include a footnote explaining that the results are measured from the date Capital Research and Management Company became the fund’s investment adviser.  The footnote will remain in the disclosure.

6.           Investment Results – page 5 of the fund’s prospectus

Comment:  When listing indexes in the results table, you may include in parenthesis next to the name of index whether the index reflects a deduction for fees, expenses or taxes.

Response:  We have updated our disclosure in response to this comment.

The changes described above will also be made to the fund’s retirement plan prospectus, to the extent the change applies to that document. Thank you for your consideration of our response to your comments.

If you have any questions please do not hesitate to contact me at (415) 393-7110 or Katie Newhall at (213) 615-0108.
 
 

Sincerely,


/s/ Patrick F. Quan
Patrick F. Quan
Secretary