co030315multi.htm


Number	SEC Request	Fund	Deutsche Response
1	When LIBOR is referenced in a derivative description or line of credit note, disclosure the specific LIBOR. In addition, disclose in a table the current LIBOR rate at period end.	Funds with derivatives or line of credit tied to LIBOR	Effective with the January 2015 shareholder reports, disclosure will include the specific LIBOR reference and a table with applicable LIBOR rates will be added.
2	For funds with waivers, are the funds able to recapture? Is so, disclose the provisions of the recapture.	All Funds with waivers	Currently there is not a recapture feature in place for any of the funds.
3	Sector vs. concentration risk. For funds with greater than 25% in a particular sector, consider adding sector risk as a principal risk	All Funds	To the extent that the Fund invests more than 25% of its assets in a particular sector, the Fund will add appropriate risk disclosure under Stock Market Risk when the Fund next updates its registration statement.
4	If material, ensure the Management Discussion of Fund Performance (MDFP) discusses the effect of derivatives on the funds' performance	All Funds	The Funds will evaluate the effect of derivatives on fund performance and consider appropriate disclosure, as necessary, in the MDFP.
5	For funds with high portfolio turn-over (>100%, year-over- year), add risk language to the prospectus	Deutsche Global Income Builder Fund	To the extent that the Fund has an annual portfolio turnover rate in excess of 100% and the portfolio manager intends to actively trade the portfolio in the future, the Fund will add appropriate risk disclosure relating to active trading when the Fund next updates its registration statement.
6 (a)	The net expense ratio in the fee table in the prospectus is inconsistent with the net expense ratio in the financial highlights	All Funds with waivers	The net ratios are different due to timing of contractual cap approval by the Funds’ Board. The Board approves contractual caps annually in September with an effective date of October 1st. Therefore, almost all funds will have multiple caps within the same fiscal year-end. The funds’ net ratios reported in the annual reports reflect a blended rate for the 12 month period and the net ratio in the prospectus fee table shows the highest possible net ratios for the period.
6(b)	The gross expense ratio in the fee table in the prospectus is inconsistent with the gross expense ratio in the financial highlights	Deutsche Strategic High Yield Tax Free Fund Deutsche Global Small Cap Growth Fund Deutsche High Income Fund	Effective 10/1/2014, the management fee for Deutsche Strategic High Yield Tax Free Fund was reduced by 0.05 % in each tier. Therefore, the prospectus fee table was updated to reflect the change in management fee and footnote was added to the table explaining the new management fee schedule. For Deutsche Global Small Cap Fund, the gross ratios in the 5/1/2014 prospectus are consistent with the gross ratios in the 10/31/13 annual report. For Deutsche High Income Fund, the gross ratios in the 2/1/2014 prospectus are consistent with the 9/30/13 annual report.
7	PIK (Payment in kind)- need to bifurcate if all or a portion of the income is paid in kind	Deutsche Core Plus Income Fund	Effective with the January 2015 shareholder reports, securities identified as PIKs in the Schedule of Investments will disclose, if applicable, the portion of the income paid in cash.
8	ROCSOP- Suggest disclosing ROCSOP adjustment in the notes to the financial statements	All Funds	In the funds financial statements, we include the primary reasons for book to tax differences but do not include the actual ROCSOP adjustments. We believe this approach is appropriate.
9	Allocation of Trust level expenses. Current disclosure states that Trust expenses which cannot be directly attributed to a fund are apportioned among the funds in the Trust based upon relative net assets or other appropriate measurers. What are these other appropriate measures? Enhance disclosure to expand other appropriate measures.	All Funds	All trust level expenses are allocated based on average net assets with the exception of Federal Registration Fee, which is allocated based on a percentage of net subscriptions among impacted funds, and regulatory filing fees, which are allocated based on straight line across funds within the same series. We feel the current disclosure is appropriate.
10	Fair Value Measurements Hierarchy. Add additional detail for class of security if entire class is not all is one level	All Funds	If material, the Funds will add additional detail to the leveling detail.
11	On the Statement of Assets and Liabilities, include on a separate line item restricted cash, if any	Daily Assets Fund Institutional	The cash held by Daily Assets Fund Institutional as of 6/30/14 was not restricted. Restricted cash, if any, is broken out on the Statement of Assets and Liabilities.
12	Is the Lehman receivable for Deutsche Communications Fund still realizable?	Deutsche Communications Fund	Based on discussions with our outside counsel who has contacted the bankruptcy administrator, we believe the receivable is realizable.
13	For funds with return of capital distributions, were the funds in compliance with Rule 19a-1?	All funds	Yes, the funds have written procedures designed to be in compliance with Rule 19A-1. At the time of distribution if the character of the distribution is other than net investment income, a section 19 notice accompanies the payment.
14	For funds with credit default swaps, do the funds have sufficient collateral for the maximum notional amount of the contracts?	All funds	Yes, the funds with credit default swaps have sufficient unencumbered assets to cover the notional of the credit default swaps.
15	Since Deutsche Global Inflation Fund includes "global" in its name, please confirm the fund invests in at lease three countries, including the United States, and that typically at least 40% of its net assets will be foreign investments	Deutsche Global Inflation Fund	Yes, at 9/30/14, the Deutsche Global Inflation Fund is in line with its investment policy set out in the fund's Statement of Additional Information. The fund's investment policy states that under normal conditions, the fund will have investment exposure to at least three countries, including the United States, and combined direct and indirect foreign exposure to foreign securities, foreign currencies and other foreign investments (measured on a gross basis) equal to at least over 40% of the fund's net assets.