0000906304-12-000353.txt : 20120620 0000906304-12-000353.hdr.sgml : 20120620 20120215161650 ACCESSION NUMBER: 0000906304-12-000353 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20120215 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ROYCE FUND CENTRAL INDEX KEY: 0000709364 IRS NUMBER: 133139046 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 745 FIFTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10151 BUSINESS PHONE: 2123557311 MAIL ADDRESS: STREET 1: 745 FIFTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10151 FORMER COMPANY: FORMER CONFORMED NAME: ROYCE VALUE FUND INC DATE OF NAME CHANGE: 19851103 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ROYCE VALUE TRUST INC CENTRAL INDEX KEY: 0000804116 IRS NUMBER: 133356097 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 745 FIFTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10151 BUSINESS PHONE: 2123557311 MAIL ADDRESS: STREET 1: 745 FIFTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10151 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ROYCE FOCUS TRUST INC CENTRAL INDEX KEY: 0000825202 IRS NUMBER: 592876580 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: C/O ROYCE & ASSOCIATES, LLC STREET 2: 745 FIFTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10151 BUSINESS PHONE: 2125084578 MAIL ADDRESS: STREET 1: C/O ROYCE & ASSOCIATES, LLC STREET 2: 745 FIFTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10151 FORMER COMPANY: FORMER CONFORMED NAME: ROYCE GLOBAL TRUST INC DATE OF NAME CHANGE: 19961203 FORMER COMPANY: FORMER CONFORMED NAME: ALL SEASONS GLOBAL FUND INC DATE OF NAME CHANGE: 19950803 FORMER COMPANY: FORMER CONFORMED NAME: AMERICAS ALL SEASON FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ROYCE MICRO-CAP TRUST, INC /MD/ CENTRAL INDEX KEY: 0000912147 IRS NUMBER: 133739778 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ROYCE MICRO-CAP TRUST, INC. STREET 2: 745 FIFTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10151 BUSINESS PHONE: 2124084587 MAIL ADDRESS: STREET 1: ROYCE MICRO-CAP TRUST, INC. STREET 2: 745 FIFTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10151 FORMER COMPANY: FORMER CONFORMED NAME: ROYCE MICRO CAP TRUST INC /MD/ DATE OF NAME CHANGE: 20010430 FORMER COMPANY: FORMER CONFORMED NAME: ROYCE OTC MICRO CAP FUND INC DATE OF NAME CHANGE: 19930917 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ROYCE CAPITAL FUND CENTRAL INDEX KEY: 0001006387 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: C/O ROYCE & ASSOCIATES, LLC STREET 2: 745 FIFTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10151 BUSINESS PHONE: 2125084578 MAIL ADDRESS: STREET 1: C/O ROYCE & ASSOCIATES, LLC STREET 2: 745 FIFTH AVENUE CITY: NEW YORK STATE: NY ZIP: 10151 CORRESP 1 filename1.htm secltrannual212.htm
The Royce Funds
745 Fifth Avenue
New York, NY 10151
      212-508-4500
      800-221-4268
 e-mail: funds@roycefunds.com
            website: www.roycefunds.com


 
February 15, 2012



Securities and Exchange Commission
Attn:  Mr. Kevin Rupert
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549

Re:
Annual Report to Shareholders for the year ended December 31, 2010 for each of The Royce Fund (File No. 811-03599), Royce Capital Fund (File No. 811-07537), Royce Value Trust, Inc. (File No. 811-04875), Royce Micro-Cap Trust, Inc. (File No. 811-08030) and Royce Focus Trust, Inc. (File No. 811-05379)
Dear Mr. Rupert:

        At your request, in connection with the staff’s comments relating to each of the above-referenced Annual Reports to Shareholders, set forth below are the staff’s comments and the relevant Funds' responses.  The Funds acknowledge that (i) each is responsible for the adequacy and accuracy of the disclosure in their Annual Reports to Shareholders; (ii) SEC staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the SEC from taking any action with respect to the Annual Reports to Shareholders; and (iii) no Fund may assert this action as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.

All Royce Funds:

Comment:   In the notes to the Fund's financial statements, please add disclosure to clarify that no affiliate of Royce & Associates, LLC, the Funds' investment adviser, receives any portion of the income generated by the Funds' securities lending activities.

 
Response:  Beginning with each Fund's Annual Report to Shareholders for the year ended December 31, 2011, language will be added to address this comment.


The Royce Fund:

 
Comment:  Please confirm whether the performance of Royce Low-Priced Stock Fund that is set forth in the line graph depicting the value of $10,000 invested in the Fund since its inception is for the Fund's Service Class (its oldest Class).

 
Response:  Confirmed.

        We believe that the proposed modifications to the Annual Reports to Shareholders are responsive to the staff’s comments.  Please direct any further communication relating to this filing to either of the undersigned at (212) 508-4572 and (212) 508-4578, respectively.

 
Very truly yours,
 
/s/ John D. Diederich
 
John D. Diederich
Vice President and
Treasurer
 
/s/ John E. Denneen
 
John E. Denneen
Secretary


cc:
Charles M. Royce
 
Mary Macchia
 
Frank P. Bruno, Esq.