0000950137-09-003735.txt : 20130226 0000950137-09-003735.hdr.sgml : 20130226 20090508113515 ACCESSION NUMBER: 0000950137-09-003735 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20090508 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SELIGMAN COMMON STOCK FUND INC CENTRAL INDEX KEY: 0000014358 IRS NUMBER: 134971230 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: BROAD STREET INVESTING CORP DATE OF NAME CHANGE: 19820426 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RIVERSOURCE DIVERSIFIED INCOME SERIES INC CENTRAL INDEX KEY: 0000049697 IRS NUMBER: 411237361 STATE OF INCORPORATION: MN FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: RIVERSOURCE DIVERSIFIED INCOME SERIES, INC. DATE OF NAME CHANGE: 20060504 FORMER COMPANY: FORMER CONFORMED NAME: AXP FIXED INCOME SERIES INC DATE OF NAME CHANGE: 20021118 FORMER COMPANY: FORMER CONFORMED NAME: AXP BOND FUND INC DATE OF NAME CHANGE: 20000829 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RIVERSOURCE LARGE CAP SERIES, INC. CENTRAL INDEX KEY: 0000049702 IRS NUMBER: 410962638 STATE OF INCORPORATION: MN FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: AXP GROWTH SERIES INC/MN DATE OF NAME CHANGE: 20001011 FORMER COMPANY: FORMER CONFORMED NAME: AXP GROWTH FUND INC DATE OF NAME CHANGE: 20000829 FORMER COMPANY: FORMER CONFORMED NAME: IDS GROWTH FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RIVERSOURCE INVESTMENT SERIES, INC. CENTRAL INDEX KEY: 0000052347 IRS NUMBER: 410839315 STATE OF INCORPORATION: MN FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: AXP INVESTMENT SERIES INC DATE OF NAME CHANGE: 19991124 FORMER COMPANY: FORMER CONFORMED NAME: IDS INVESTMENT SERIES INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: IDS MUTUAL INC/NEW DATE OF NAME CHANGE: 19911124 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SELIGMAN INCOME & GROWTH FUND INC CENTRAL INDEX KEY: 0000100852 IRS NUMBER: 135534276 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: SELIGMAN INCOME FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: UNION INCOME FUND INC DATE OF NAME CHANGE: 19820426 FORMER COMPANY: FORMER CONFORMED NAME: WHITEHALL FUND INC DATE OF NAME CHANGE: 19740826 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SELIGMAN GROWTH FUND INC CENTRAL INDEX KEY: 0000316411 IRS NUMBER: 135267160 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: NATIONAL INVESTORS CORP DATE OF NAME CHANGE: 19820426 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SELIGMAN MUNICIPAL FUND SERIES INC CENTRAL INDEX KEY: 0000726291 IRS NUMBER: 133177004 STATE OF INCORPORATION: MD FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-2429 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: SELIGMAN TAX EXEMPT FUND SERIES INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RIVERSOURCE HIGH YIELD INCOME SERIES, INC. CENTRAL INDEX KEY: 0000728374 IRS NUMBER: 411458705 STATE OF INCORPORATION: MN FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: AXP HIGH YIELD INCOME SERIES INC DATE OF NAME CHANGE: 20021118 FORMER COMPANY: FORMER CONFORMED NAME: AXP EXTRA INCOME FUND INC/MN DATE OF NAME CHANGE: 20000825 FORMER COMPANY: FORMER CONFORMED NAME: IDS EXTRA INCOME FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RIVERSOURCE STRATEGY SERIES, INC. CENTRAL INDEX KEY: 0000740146 IRS NUMBER: 416287631 STATE OF INCORPORATION: MN FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: AXP STRATEGY SERIES INC DATE OF NAME CHANGE: 20000829 FORMER COMPANY: FORMER CONFORMED NAME: IDS STRATEGY FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SELIGMAN MUNICIPAL SERIES TRUST CENTRAL INDEX KEY: 0000750756 IRS NUMBER: 133409771 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: SELIGMAN TAX EXEMPT SERIES TRUST DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: SELIGMAN CALIFORNIA TAX EXEMPT FUND SERIES DATE OF NAME CHANGE: 19890803 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SELIGMAN HIGH INCOME FUND SERIES CENTRAL INDEX KEY: 0000752372 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RIVERSOURCE GOVERNMENT INCOME SERIES INC CENTRAL INDEX KEY: 0000764802 IRS NUMBER: 412021315 STATE OF INCORPORATION: MN FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: RIVERSOURCE GOVERNMENT INCOME SERIES, INC. DATE OF NAME CHANGE: 20060504 FORMER COMPANY: FORMER CONFORMED NAME: AXP GOVERNMENT INCOME SERIES INC DATE OF NAME CHANGE: 20021118 FORMER COMPANY: FORMER CONFORMED NAME: AXP FEDERAL INCOME FUND INC /MN/ DATE OF NAME CHANGE: 20000829 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SELIGMAN PENNSYLVANIA MUNICIPAL FUND SERIES CENTRAL INDEX KEY: 0000793701 IRS NUMBER: 136872089 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: SELIGMAN PENNSYLVANIA TAX EXEMPT FUND SERIES DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SELIGMAN NEW JERSEY MUNICIPAL FUND INC CENTRAL INDEX KEY: 0000813240 IRS NUMBER: 000000000 FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: SELIGMAN NEW JERSEY TAX EXEMPT FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RIVERSOURCE GLOBAL SERIES INC CENTRAL INDEX KEY: 0000842918 IRS NUMBER: 411850486 STATE OF INCORPORATION: MN FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRSE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRSE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: RIVERSOURCE GLOBAL SERIES, INC. DATE OF NAME CHANGE: 20060504 FORMER COMPANY: FORMER CONFORMED NAME: AXP GLOBAL SERIES INC DATE OF NAME CHANGE: 19991228 FORMER COMPANY: FORMER CONFORMED NAME: IDS GLOBAL SERIES INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RIVERSOURCE MARKET ADVANTAGE SERIES, INC. CENTRAL INDEX KEY: 0000854669 IRS NUMBER: 411946880 STATE OF INCORPORATION: MN FISCAL YEAR END: 0131 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: AXP MARKET ADVANTAGE SERIES INC DATE OF NAME CHANGE: 19991124 FORMER COMPANY: FORMER CONFORMED NAME: IDS MARKET ADVANTAGE SERIES INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: IDS INDEX ADVANTAGE SERIES INC DATE OF NAME CHANGE: 19900201 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SELIGMAN GLOBAL FUND SERIES INC CENTRAL INDEX KEY: 0000881466 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: SELIGMAN HENDERSON GLOBAL FUND SERIES INC DATE OF NAME CHANGE: 19930721 FORMER COMPANY: FORMER CONFORMED NAME: SELIGMAN INTERNATIONAL FUND SERIES INC DATE OF NAME CHANGE: 19920717 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SELIGMAN VALUE FUND SERIES INC CENTRAL INDEX KEY: 0001031594 IRS NUMBER: 133927140 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SELIGMAN ASSET ALLOCATION SERIES, INC. CENTRAL INDEX KEY: 0001092633 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50506 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50506 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: SELIGMAN TIME HORIZON/HARVESTER SERIES INC DATE OF NAME CHANGE: 20030625 FORMER COMPANY: FORMER CONFORMED NAME: SELIGMAN TIME HORIZON HARVESTER SERIES INC DATE OF NAME CHANGE: 19990805 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RIVERSOURCE INTERNATIONAL MANAGERS SERIES, INC. CENTRAL INDEX KEY: 0001140531 IRS NUMBER: 412009895 STATE OF INCORPORATION: MN FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 61-2671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: AXP PARTNERS INTERNATIONAL SERIES INC DATE OF NAME CHANGE: 20010514 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SELIGMAN CORE FIXED INCOME FUND, INC CENTRAL INDEX KEY: 0001142702 IRS NUMBER: 134179240 FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 612-671-4321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: SELIGMAN INVESTMENT GRADE FIXED INCOME FUND INC DATE OF NAME CHANGE: 20010614 CORRESP 1 filename1.txt May 8, 2009 Ms. Patsy Mengiste Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 ATTN.: Document Control - EDGAR RE: RIVERSOURCE DIVERSIFIED INCOME SERIES, INC. (FILE NOS. 002-51586 / 811-02503) N-CSR for the annual report for the period ended Aug. 31, 2008 for RiverSource Diversified Bond Fund RIVERSOURCE GLOBAL SERIES, INC. (FILE NOS. 033-25824 / 811-05696) N-CSR for the annual reports for the period ended Oct. 31, 2008 for the following series: RiverSource Global Technology Fund, Threadneedle Emerging Markets Fund and Threadneedle Global Equity Fund RIVERSOURCE GOVERNMENT INCOME SERIES, INC. (FILE NOS. 002-96512 / 811-04260) N-CSR for the annual report for the period ended May 31, 2008 for RiverSource Short Duration U.S. Government Fund RIVERSOURCE HIGH YIELD INCOME SERIES, INC. (FILE NOS. 002-86637 / 811-03848) N-CSR for the annual report for the period ended May 31, 2008 for RiverSource High Yield Bond Fund RIVERSOURCE INTERNATIONAL MANAGERS SERIES, INC. (FILE NOS. 333-64010 / 811-10427) N-CSR for the annual report for the period ended Oct. 31, 2008 for RiverSource Partners International Select Growth Fund RIVERSOURCE INVESTMENT SERIES, INC. (FILE NOS. 002-11328 / 811-00054) N-CSR for the annual report for the period ended Sept. 30, 2008 for RiverSource Balanced Fund RIVERSOURCE LARGE CAP SERIES, INC. (FILE NOS. 002-38355 / 811-02111) N-CSR for the annual reports for the period ended July 31, 2008 for the following series: RiverSource Growth Fund, RiverSource Disciplined Equity Fund, RiverSource Large Cap Equity Fund and RiverSource Large Cap Value Fund RIVERSOURCE MARKET ADVANTAGE SERIES, INC. (FILE NOS. 033-30770 / 811-05897) N-CSR for the annual report for the period ended Jan. 31, 2009 for the following series: RiverSource Portfolio Builder Conservative Fund, RiverSource Portfolio Builder Moderate Conservative Fund, RiverSource Portfolio Builder Moderate Fund, RiverSource Portfolio Builder Moderate Aggressive Fund, RiverSource Portfolio Builder Aggressive Fund and RiverSource Portfolio Builder Total Equity Fund RIVERSOURCE STRATEGY SERIES, INC. (FILE NOS. 002-89288 / 811-03956) N-CSR for the annual reports for the period ended March 31, 2008 for the following series: RiverSource Equity Value Fund and RiverSource Small Cap Advantage Fund SELIGMAN ASSET ALLOCATION SERIES, INC. (FILE NOS. 333-85111/ 811-09545) N-CSR for the annual report for the period ended Dec. 31, 2008 for the following series: Seligman Asset Allocation Aggressive Growth Fund, Seligman Asset Allocation Balanced Fund, Seligman Asset Allocation Growth Fund and Seligman Asset Allocation Moderate Growth Fund SELIGMAN COMMON STOCK FUND, INC. (FILE NOS. 002-10835 / 811-00234) N-CSR for the annual report for the period ended Dec. 31, 2008 for Seligman Common Stock Fund, Inc. SELIGMAN CORE FIXED INCOME FUND, INC. (FILE NOS. 333-63546 / 811-10423) N-CSR for the annual report for the period ended Sept. 30, 2008 for Seligman Core Fixed Income Fund, Inc. SELIGMAN GLOBAL FUND SERIES, INC. (FILE NOS. 033-44186 / 811-06485) N-CSR for the annual report for the period ended Oct. 31, 2008 for the following series: Seligman Emerging Markets Fund, Seligman Global Growth Fund, Seligman Global Smaller Companies Fund, Seligman Global Technology Fund and Seligman International Growth Fund SELIGMAN GROWTH FUND, INC. (FILE NOS. 002-10836 / 811-00229) N-CSR for the annual report for the period ended Dec. 31, 2008 for Seligman Growth Fund, Inc. SELIGMAN HIGH INCOME FUND SERIES (FILE NOS. 002-93076 / 811-04103) N-CSR for the annual reports for the period ended Dec. 31, 2008 for the following series: Seligman High-Yield Fund and Seligman U.S. Government Securities Fund SELIGMAN INCOME AND GROWTH FUND, INC. (FILE NOS. 002-10837 / 811-00525) N-CSR for the annual report for the period ended Dec. 31, 2008 for Seligman Income and Growth Fund, Inc. SELIGMAN MUNICIPAL FUND SERIES, INC. (FILE NOS. 002-86008 / 811-03828) N-CSR for the annual report for the period ended Sept. 30, 2008 for the following series: Seligman Colorado Fund, Seligman Georgia Fund, Seligman Louisiana Fund, Seligman Maryland Fund, Seligman Massachusetts Fund, Seligman Michigan Fund, Seligman Minnesota Fund, Seligman Missouri Fund, Seligman National Fund, Seligman New York Fund, Seligman Ohio Fund, Seligman Oregon Fund and Seligman South Carolina Fund SELIGMAN MUNICIPAL SERIES TRUST (FILE NOS. 002-92569 / 811-04250) SELIGMAN NEW JERSEY MUNICIPAL FUND, INC. (FILE NOS. 033-13401 / 811-05126) SELIGMAN PENNSYLVANIA MUNICIPAL FUND SERIES (FILE NOS. 033-05793 / 811-04666) N-CSR for the annual report for the period ended Sept. 30, 2008 for the following funds: Seligman Municipal Series Trust California High-Yield Fund, California Quality Fund, Florida Fund and North Carolina Fund Seligman New Jersey Municipal Fund, Inc. Seligman Pennsylvania Municipal Fund Series SELIGMAN VALUE FUND SERIES, INC. (FILE NOS. 333-20621 / 811-08031) N-CSR for the annual report for the period ended Dec. 31, 2008 for the following series: Seligman Large-Cap Value Fund and Seligman Smaller-Cap Value Fund Dear Ms. Mengiste: This letter responds to your comments received by telephone on April 3, 2009 for the above-referenced Funds' annual reports filed on Form N-CSR for the periods indicated. COMMENT 1: For the Seligman Municipal Funds' shareholder reports, please provide the management's discussion of fund performance (MDFP) separately for each Fund. RESPONSE: The Seligman Municipal Funds are generally managed in a consistent manner with regard to quality, duration and type of bonds. Where differences exist, they are commented upon if they have a significant effect on performance. For example, the last paragraph of the MDFP for the report including Seligman Municipal Series Trust notes the impact on various funds of their relative holdings of pollution control/industrial development bonds. Future reports will provide additional, separate commentary on specific Funds, as appropriate. COMMENT 2: For applicable Fund shareholder reports, please revise the graph depicting the Fund's long-term performance to improve the ability to distinguish between the lines representing the Fund and its comparative indices. RESPONSE: The graph will be redesigned to better distinguish between the lines representing the Fund and its comparative indices. Design changes may include one or more of the following: varying line thickness and shading, minimizing the scale used for the vertical axis and increasing the frequency of plot points. COMMENT 3: In general, at fiscal year end or subsequent thereto, have the Funds experienced any issues with regard to liquidity, valuation, pricing or redemptions? If so, to what extent? RESPONSE: During the period, no Fund experienced liquidity issues impacting its investment operations or its ability to satisfy redemption requests, and no Fund experienced material pricing or valuation issues. Because of the volatility of the recent market environment, however, Fund management has spent increased time and effort to assess the adequacy and sufficiency of its pricing and valuation procedures. COMMENT 4: In particular with regards to defaulted portfolio securities, at fiscal year end or subsequent thereto, have the Funds experienced any material issues with regard to pricing or liquidity? If so, to what extent? RESPONSE: During the period, no Fund experienced a material increase in its exposure to defaulted securities (i.e., no Fund experienced a liquidity issue as a result of defaulted portfolio securities), and there were no issues related to the pricing and valuation of such securities. Fund management continues to adhere to its process for monitoring defaulted portfolio securities. COMMENT 5: With regards to securities on loan, please describe the Funds' policy with regard to the collateral received. Is the collateral invested? Have there been any problems with pricing of the collateral? Also, please explain whether the Funds' retain voting authority for securities on loan. RESPONSE: The RiverSource and Threadneedle Funds have a Securities Lending Agreement (the Agreement) with JPMorgan Chase Bank, National Association (JPMorgan) that authorizes JPMorgan as securities lending agent to lend securities to authorized borrowers on behalf of these Funds. In January 2009, the Board approved this Agreement be adopted for the Seligman Funds. The Seligman Funds will begin lending following their transition to JPMorgan as custodian, which is expected to occur in the second or third quarter 2009. All securities are eligible to be loaned. The Funds retain discretionary authority to recall securities on loan in order to vote proxies. The Funds have not had any issues with collateral including the pricing of collateral. Additional background regarding the securities lending program is included in the shareholder reports for those Funds that participate in the securities lending program substantially as follows. Pursuant to the Agreement, all loaned securities are initially collateralized in an amount equivalent to 102% (for securities denominated in U.S. dollars) or 105% (for all other securities) of the value of the loaned securities, including accrued interest in the case of fixed income securities. Collateral is maintained over the life of the loan thereafter in an amount not less than 100% of the market value of loaned securities, as determined at the close of each business day, except to the extent that a collateral shortfall is due to a diminution in the market value of authorized investments in which cash collateral is invested. Any additional collateral required to maintain those levels due to market fluctuations of the loaned securities is delivered the following business day. Collateral is either in the form of cash or U.S. government securities. Cash collateral received is invested by the lending agent on behalf of the Fund into authorized investments pursuant to the Agreement. The investments made with the cash collateral are listed on the Portfolio of Investments and the value of cash collateral received at period end is disclosed on the Statement of Assets and Liabilities along with the related obligation to return the collateral upon return of the securities loaned. Pursuant to the Agreement, the Fund receives income for lending its securities either in the form of fees or by earning interest on invested cash collateral, net of negotiated rebates paid to borrowers and fees paid to the lending agent for services provided and any other securities lending expenses. Income earned from securities lending is included in the Statement of Operations. The Fund also continues to earn interest and dividends on the securities loaned. Risks of delay in recovery of securities or even loss of rights in the securities may occur should the borrower of the securities fail financially. Risks may also arise to the extent that the value of the securities loaned increases above the value of the collateral received. JPMorgan will indemnify the Fund from losses resulting from a borrower's failure to return a loaned security when due. Such indemnification does not extend to losses associated with declines in the value of cash collateral investments. Loans are subject to termination by the Funds or the borrower at any time, and are, therefore, not considered to be illiquid investments. COMMENT 6: To the extent a Fund has a high rate of portfolio turnover, please highlight it in the MDFP. RESPONSE: Funds that have experienced a high rate of portfolio turnover during the last fiscal year will highlight the portfolio turnover in the MDFP. COMMENT 7: Please supplementally describe the circumstances under which cash collateral for securities lending is held with the broker instead of the custodian. RESPONSE: JPMorgan acts as the custodian and the securities lending agent for the RiverSource Funds. As described above in the Response to Comment 5, it is currently anticipated that the Seligman Funds will begin participating in JPMorgan's securities lending program following their transition to JPMorgan as custodian, which is expected to occur in the second or third quarter 2009. Under the Agreement, JPMorgan holds cash collateral from securities lending for each Fund in a segregated account that is separate from each Fund's primary custodial accounts. Cash collateral is not held by brokers that receive loaned securities. COMMENT 8: In the Notes to Portfolio of Investments, please include the percentage of Fund assets held in illiquid securities. RESPONSE: The percentage of Fund assets held in illiquid securities will be added to the applicable footnote to the list of Portfolio of Investments. COMMENT 9: For the Seligman Fund shareholder reports, please explain whether mortgage dollar rolls are included in Fund borrowing. RESPONSE: The Seligman Funds account for mortgage dollar rolls as discrete transactions and record a gain or loss on the sale of the initial security purchased. The payable for the new security purchased is included within the line item "Payable for securities purchased" in the Statement of Assets and Liabilities. They are not treated as borrowings. If the settlement date of the new security purchased is beyond trade date + 3, the Fund segregates assets of equal or greater value to cover its purchase obligation. COMMENT 10: For the RiverSource and Threadneedle Fund shareholder reports, supplementally explain what "worst of call options" are. RESPONSE: A worst-of-call option is an over-the-counter options contract comprised of a basket, or bundle, of call options all with the same expiration dates but for different underlying assets. On the expiration date, only the worst performing option (the option where the percentage move in the price of the underlying asset from trade date to expiration date is the least) will be exercised. In connection with the N-CSR filings identified above for the above-referenced Registrants, each Registrant hereby acknowledges the following: The disclosures in the filing are the responsibility of the Registrant and the Registrant is fully responsible for the adequacy or accuracy of the disclosures in this filing. The Registrant represents to the Commission that comments made by the Commission, or the staff acting pursuant to delegated authority, or changes to disclosure in response to staff comments in the filing reviewed by the staff, do not foreclose the Commission from taking any action with respect to the filing, and the Registrant represents that it will not assert this action as a defense in any proceeding initiated by the Commission or any person, under the federal securities laws of the United States. If you have any questions, please contact either me at 612-671-4321 or Heidi Brommer at 612-671-2403. Sincerely, /s/ Christopher O. Petersen ------------------------------------- Christopher O. Petersen Vice President and Group Counsel Ameriprise Financial, Inc.