-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, LNs0Xwbhj6KpcsrLcTS/gPEkoDDj9zjDOU369O2omTymcVL52oyXA6iHDZ6fkuj7 pq6IwENPSb0mvrKiUxJg3g== 0000899681-06-000771.txt : 20091117 0000899681-06-000771.hdr.sgml : 20091117 20061221141257 ACCESSION NUMBER: 0000899681-06-000771 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20061221 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DREYFUS BOND FUNDS INC CENTRAL INDEX KEY: 0000075176 IRS NUMBER: 132866680 STATE OF INCORPORATION: MD FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 200 PARK AVENUE STREET 2: THE DREYFUS CORPORATION CITY: NEW YORK STATE: NY ZIP: 10166 BUSINESS PHONE: 2129228297 MAIL ADDRESS: STREET 1: C/O DREYFUS CORP STREET 2: 200 PARK AVENUE, 8TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10166 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS MUNICIPAL BOND FUND DATE OF NAME CHANGE: 19930125 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS TAX EXEMPT BOND FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: OVERBROOK BOND FUND INC DATE OF NAME CHANGE: 19760923 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DREYFUS PREMIER CALIFORNIA TAX EXEMPT BOND FUND INC CENTRAL INDEX KEY: 0000720064 IRS NUMBER: 133171422 STATE OF INCORPORATION: NY FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: THE DREYFUS CORPORATION STREET 2: 200 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10166 BUSINESS PHONE: 2129226850 MAIL ADDRESS: STREET 1: C/O DREYFUS CORP STREET 2: 200 PARK AVENUE, 8TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10166 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS PREMIER CALIFORNIA TAX EXEMPT BOND FUND INC DATE OF NAME CHANGE: 20041217 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS CALIFORNIA TAX EXEMPT BOND FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DREYFUS GOVERNMENT CASH MANAGEMENT Funds CENTRAL INDEX KEY: 0000740766 IRS NUMBER: 000000000 FISCAL YEAR END: 0131 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: THE DREYFUS CORPORATION STREET 2: 200 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10166 BUSINESS PHONE: 2129228297 MAIL ADDRESS: STREET 1: C/0 DREYFUS CORP STREET 2: 200 PARK AVENUE, 8TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10166 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS GOVERNMENT CASH MANAGEMENT DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS GOVERNMENT CASH MANAGEMENT INC DATE OF NAME CHANGE: 19880425 FORMER COMPANY: FORMER CONFORMED NAME: CORNWALL GOVERNMENT SECURITIES MONEY MARKET FUND INC DATE OF NAME CHANGE: 19850310 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DREYFUS GNMA FUND INC CENTRAL INDEX KEY: 0000762156 IRS NUMBER: 133281750 STATE OF INCORPORATION: NY FISCAL YEAR END: 0430 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 200 PARK AVE STREET 2: THE DREYFUS CORPORATION CITY: NEW YORK STATE: NY ZIP: 10166 BUSINESS PHONE: 2129226850 MAIL ADDRESS: STREET 1: THE DREYFUS CORPORATION STREET 2: 200 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10166 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS GNMA FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DREYFUS TREASURY CASH MANAGEMENT CENTRAL INDEX KEY: 0000796251 IRS NUMBER: 000000000 STATE OF INCORPORATION: NY FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: THE DREYFUS CORPORATION STREET 2: 200 PARKA VENUE CITY: NEW YORK STATE: NY ZIP: 10166 BUSINESS PHONE: 2129228297 MAIL ADDRESS: STREET 1: C/O DREYFUS CORP STREET 2: 200 PARK AVENUE, 8TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10166 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS TREASURY CASH MANAGEMENT DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DREYFUS GENERAL NEW YORK MUNICIPAL MONEY MARKET FUND CENTRAL INDEX KEY: 0000803950 IRS NUMBER: 000000000 STATE OF INCORPORATION: NY FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: THE DREYFUS CORPORATION STREET 2: 200 PARKA VENUE CITY: NEW YORK STATE: NY ZIP: 10166 BUSINESS PHONE: 2129226785 MAIL ADDRESS: STREET 1: C/O DREYFUS CORP STREET 2: 200 PARK AVENUE, 8TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10166 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS GENERAL NEW YORK MUNICIPAL MONEY MARKET FUND DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: GENERAL NEW YORK TAX EXEMPT MONEY MARKET FUND INC DATE OF NAME CHANGE: 19900401 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GENERAL CALIFORNIA MUNICIPAL MONEY MARKET FUND CENTRAL INDEX KEY: 0000803951 IRS NUMBER: 000000000 STATE OF INCORPORATION: NY FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 200 PARK AVE. STREET 2: THE DREYFUS CORPORATION CITY: NEW YORK STATE: NY ZIP: 10166 BUSINESS PHONE: 2129226785 MAIL ADDRESS: STREET 1: C/O DREYFUS CORP STREET 2: 200 PARK AVENUE, 8TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10166 FORMER COMPANY: FORMER CONFORMED NAME: GENERAL CALIFORNIA TAX EXEMPT MONEY MARKET FUND DATE OF NAME CHANGE: 19900617 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DREYFUS PREMIER STATE MUNICIPAL BOND FUND CENTRAL INDEX KEY: 0000806176 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 0430 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: C/O DREYFUS CORP STREET 2: 200 PARK AVE 8TH FL. W. CITY: NEW YORK STATE: NY ZIP: 10166 BUSINESS PHONE: 2129226847 MAIL ADDRESS: STREET 1: C/O DREYFUS CORP STREET 2: 200 PARK AVE. , 8TH FL. W. CITY: NEW YORK STATE: NY ZIP: 10166 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS PREMIER STATE MUNICIPAL BOND FUND DATE OF NAME CHANGE: 19970506 FORMER COMPANY: FORMER CONFORMED NAME: PREMIER STATE MUNICIPAL BOND FUND DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: PREMIER SERIES TAX EXEMPT BOND FUND DATE OF NAME CHANGE: 19870224 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DREYFUS CASH MANAGEMENT PLUS INC CENTRAL INDEX KEY: 0000820482 IRS NUMBER: 000000000 STATE OF INCORPORATION: NY FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: THE DREYFUS CORPORATION STREET 2: 200 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10166 BUSINESS PHONE: 2129228297 MAIL ADDRESS: STREET 1: C/O DREYFUS CORP STREET 2: 200 PARK AVENUE, 8TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10166 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DREYFUS PREMIER NEW JERSEY MUNICIPAL BOND FUND INC CENTRAL INDEX KEY: 0000828475 IRS NUMBER: 000000000 STATE OF INCORPORATION: NY FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: THE DREYFUS CORPORATION STREET 2: 200 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10166 BUSINESS PHONE: 2129226726 MAIL ADDRESS: STREET 1: C/O DREYFUS CORP STREET 2: 200 PARK AVENUE, 8TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10166 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS PREMIER NEW JERSEY MUNICIPAL BOND FUND INC DATE OF NAME CHANGE: 20030121 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS NEW JERSEY MUNICIPAL BOND FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS NEW JERSEY TAX EXEMPT BOND FUND INC DATE OF NAME CHANGE: 19900926 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DREYFUS MUNICIPAL FUNDS INC CENTRAL INDEX KEY: 0000878092 IRS NUMBER: 000000000 STATE OF INCORPORATION: NY FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 200 PARK AVE STREET 2: DREYFUS CORP CITY: NEW YORK STATE: NY ZIP: 10166 BUSINESS PHONE: 2129226801 MAIL ADDRESS: STREET 1: DREYFUS CORP STREET 2: 200 PARK AVENUE, 8TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10166 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS BASIC MUNICIPAL MONEY MARKET FUND INC /MD/ DATE OF NAME CHANGE: 19930329 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS INVESTORS MUNICIPAL MONEY MARKET FUND INC DATE OF NAME CHANGE: 19920911 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS BASIC MUNICIPAL MONEY MARKET FUND INC DATE OF NAME CHANGE: 19920403 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Advantage Funds, Inc. CENTRAL INDEX KEY: 0000914775 IRS NUMBER: 133851784 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: THE DREYFUS CORPORATION STREET 2: 200 PARK AVENUE 8TH FLOOR WEST CITY: NEW YORK STATE: NY ZIP: 10166 BUSINESS PHONE: 2129226754 MAIL ADDRESS: STREET 1: 200 PARK AVENUE, 8TH FLOOR STREET 2: THE DREYFUS CORPORATION CITY: NEW YORK STATE: NY ZIP: 10166 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS GROWTH & VALUE FUNDS INC DATE OF NAME CHANGE: 19951004 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS FOCUS FUNDS INC DATE OF NAME CHANGE: 19940304 FORMER COMPANY: FORMER CONFORMED NAME: DREYFUS GROWTH & VALUE FUND INC DATE OF NAME CHANGE: 19931116 CORRESP 1 filename1.htm CORRESP

STROOCK & STROOCK & LAVAN LLP
180 Maiden Lane
New York, New York 10038

December 21, 2006

VIA EDGAR

Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Christina DiAngelo

Re: Advantage Funds, Inc. (File Nos.: 811-7123; 333-138942)
Dreyfus Bond Funds, Inc. (File Nos.: 811-2653; 333-138959)
Dreyfus Cash Management Plus, Inc. (File Nos.: 811-5295; 333-138947)
Dreyfus General New York Municipal Money Market Fund (File Nos.: 811-4870; 333-138941)
Dreyfus GNMA Fund, Inc. (File Nos.: 811-4215; 333-138934)
Dreyfus Government Cash Management Funds (File Nos.: 811-3964; 33-138946)
Dreyfus Municipal Funds, Inc. (File Nos.: 811-6377; 333-138965)
Dreyfus Premier California Tax Exempt Bond Fund, Inc. (File Nos.: 811-3757; 333-138939)
Dreyfus Premier New Jersey Municipal Bond Fund, Inc. (File Nos.: 811-5454; 333-138920)
Dreyfus Premier State Municipal Bond Fund (File Nos.: 811-4906, 333-138929)
Dreyfus Treasury Cash Management (File Nos.: 811-4723; 333-138945)
General California Municipal Money Market Fund (File Nos.: 811-4871; 333-138938)
Registration Statements on Form N-14

Ladies and Gentlemen:

We are writing on behalf of each of the above-referenced Registrants in response to your request for supplemental information received by telephone from Christina DiAngelo of the staff (the “Staff”) of the Securities and Exchange Commission, to Nicole M. Runyan, on December 18, 2006, relating to the above-referenced Registration Statements on N-14. Set forth below are the Staff’s comments and our response thereto. Capitalized terms used herein and not otherwise defined are used with the meanings assigned to them in the Registration Statements.

Fee Tables

1.

Staff Comment. Please supplementally explain why each Acquiring Fund calculated its “annual fund operating expenses” as of July 31, 2006 instead of using the Acquiring Fund’s most recent fiscal year end.

Response. Each Acquiring Fund calculated its “annual fund operating expenses” as of July 31, 2006 to provide more current and accurate expense ratios than would have been available if the Acquiring Fund used expense ratios as of its most recent fiscal year end. Additonally, none of the Registrants' ratios as of July 31, 2006 are materially different from the Registrants' expenses ratios as of their most recent fiscal year ends.


Capitalization Tables

2.

Staff Comment. The Staff notes that each Acquiring Fund used October 31, 2006 in calculating the capitalization of its shares, shares of the Fund and the pro forma capitalization of the shares of the Acquiring Fund after the reorganization is completed. Please supplementally explain why, for the Acquiring Funds that included pro forma financial statements in the Registration Statements, the Acquiring Funds did not use the date of the pro forma financial statements in calculating the capitalization tables.

Response. Each Acquiring Fund used October 31, 2006 in calculating the capitalization tables to provide a more current and accurate estimate of the capitalization of its shares, the shares of the Fund and the pro forma capitalization of the Acquiring Fund’s shares after completion of the reorganization than would have been available if the Acquiring Fund used the date of its pro forma financial statements.


Pro Forma Financial Statements

3.

Staff Comment. Please supplementally explain why certain of the pro forma financial statements filed with the Registration Statements are not based off the most recently ended fiscal period for the Acquiring Fund.

Response. As several of the Acquiring Funds and Funds have different fiscal year ends, a decision was made to base each set of pro forma financial statements off the most current possible date, giving consideration to (i) the interest in providing shareholders more current information and (ii) the time necessary to prepare and review the pro forma financial statements for the relevant Acquiring Funds. Thus, in certain instances, the pro forma financial statements are based off a date subsequent to an Acquiring Fund’s most recently completed fiscal period.


4.

Staff Comment. For Dreyfus Municipal Funds, Inc., as there are two Funds proposed to be reorganized into the Acquiring Fund, please provide (i) pro forma financial statements reflecting the combination of all funds that are involved in the proposed combinations, based on the assumption that the shareholders of each of the Funds will approve the transaction, and (ii) revised fee tables and expense examples for every possible combination involving the Funds and the Acquiring Fund.

Response. Dreyfus Municipal Funds, Inc. will file a pre-effective amendment to its Registration Statement prior to December 27, 2006 in order to include the revised pro forma financial statements and fee tables and expense examples. As discussed with the Staff, concurrent with the filing of the pre-effective amendment, the Registrant will seek acceleration of the effective date of the Registration Statement to the earliest practical date in order to mail the Prospectus/Proxy Statement to shareholders of the Funds on a timely basis with the other Acquiring Funds.


As discussed with the Staff generally, given the large number of Registration Statements being prepared, filed, reviewed and mailed to shareholder on or about the same time, Dreyfus attempted to provide shareholders with the most currently available information, while, at the same time, electing to make the dates that such information was provided consistent across the Registration Statements. Each of the Registrants undertakes to continue to review, on a month-end basis, the financial information provided to shareholders in the Prospectus/Proxy Statements and will promptly notify shareholders of any materials changes to that information prior to the shareholder meetings to be held in March 2007.

Should members of the Staff have any questions or comments regarding our supplemental response, please contact me at 212.806.6443 or, in my absence, to David Stephens at 212.806.6138.

Very truly yours,


/s/ Nicole M. Runyan
Nicole M. Runyan

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