[Logo – American
Funds ®]
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