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EuroPacific
Growth Fund
333 South Hope
Street
Los Angeles,
California 90071-1406
Phone (213) 486
9200
Fax (213) 486
9455
Email
vpc@capgroup.com
Vincent
P. Corti
Secretary
June 6,
2009
Ms. Laura Hatch,
Staff Accountant
U.S. Securities and
Exchange Commission
100 F Street,
NE
Washington, DC
20549
Re:
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EuroPacific
Growth Fund
|
|
File
Nos. 811-03734 and
002-83847
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Dear Ms.
Hatch:
This letter is in
response to oral comments we received from you in May regarding the fund’s
Post-Effective Amendment No. 40 to the Registration Statement under the
Securities Act of 1933 and Amendment No. 40 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 have incorporated any changes to the
fund’s Registration Statement.
1. Fees
and expenses of the fund – page 1 of the fund’s prospectus.
Comment: In the
“shareholder fees” table please remove the footnote stating that Class B and
Class 529-B shares are not available for purchase.
Response: The
footnote has been removed.
2. Fees
and expenses of the fund – page 1 of the fund’s prospectus.
Comment: In the
footnote to the “annual fund operating expenses” table please indicate that the
“other expenses” for Class F-2 shares are estimated.
Response: The
footnote has been updated accordingly.
3. Principal
investment strategies – page 3 of the fund’s prospectus
Comment: The
“principal investment strategies” section of the prospectus contains the
following language:
“Normally, the fund
will invest at least 80% of its assets in securities of issuers located in
Europe and the Pacific Basin. This policy is subject to change only upon 60
days’ notice to shareholders.”
Pursuant to your
request you may move the language regarding the 60 day policy to the “investment
objective, strategies and risks” section of prospectus.
Response: The
language has been moved to the “investment objective, strategies and risks”
section of prospectus.
4. Payments
to broker-dealers and other financial intermediaries – page 7 of the fund’s
prospectus.
Comment: You
requested permission to make certain modifications to the disclosure in this
section of the prospectus. The language in this section should conform to the
language set forth in Item 8 of the revised Form N-1A. The Form permits
modifications to the statement if the modified statment contains comparable
information. However, changes should be limited to those needed to make the
statement conform to the circumstances of the fund. For example, if a fund does
not sell its shares through a bank it may omit that statement. In addition, the
term “adviser” may be used instead of “salesperson.” The substance of the
language should not be changed particularly the second sentence of the
statement.
Response: We have
updated the language accordingly. The second sentence has been revised to
conform to the statement set forth in Item 8 of Form N-1A. However, we have used
the term “individual financial adviser” rather than “salesperson.” In addition
we have revised the first sentence of the statement to say:
“If you purchase
shares of the fund through a broker-dealer or other financial intermediary (such
as a bank) the fund and the fund’s distributor
or its affiliates may pay the intermediary for the sale of fund shares
and related services.”
We
removed the reference to “related companies” because the fund does not have any
related companies.
Thank you for your
consideration of our response to your comments.
If
you have any questions please do not hesitate to contact me at (213) 486-9422 or
Tim McHale at (213) 615-0404.
Sincerely,
/s/ Vincent P.
Corti
Vincent P.
Corti
Secretary