February 28, 2013
VIA EDGAR CORRESPONDENCE
Kieran Brown
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: |
Nuveen Investment Funds, Inc. |
File Nos. 811-05309 and 033-16905
Dear Mr. Brown:
This letter responds to your comments given during a telephone conversation on February 13, 2013 regarding the registration statement filed on Form N-1A for Nuveen Investment Funds, Inc. (the Trust) with the Securities and Exchange Commission (the Commission) on December 17, 2012, which relates to Nuveen Dividend Value Fund, Nuveen Large Cap Growth Opportunities Fund and Nuveen Mid Cap Growth Opportunities Fund (collectively, the Funds), each a series of the Trust.
PROSPECTUS
COMMENT 1 FUND SUMMARIES PRINCIPAL INVESTMENT STRATEGIES
With respect to the 80% policy of the Nuveen Dividend Value Fund, explain whether the policy is implicates Rule 35d-1 of the Investment Company Act of 1940.
RESPONSE TO COMMENT 1
The Fund has not adopted an investment strategy pursuant to Rule 35d-1 because its name does not implicate Rule 35d-1 in that neither the term Dividend nor Value requires the Fund to do so.
COMMENT 2 HOW WE MANAGE YOUR MONEY WHO MANAGES THE FUND
For the portfolio manager, please clarify how long each portfolio manager has had his/her current responsibilities. If the portfolio manager has not had his/her current responsibilities for at least the past five years, please describe the portfolio managers responsibilities for the past five years.
RESPONSE TO COMMENT 2
The prospectus has been revised in response to this comment.
COMMENT 3 HOW WE MANAGE YOUR MONEY WHO MANAGES THE FUND
Please provide additional information regarding the complex-level fee breakpoints in either the prospectus or the statement of additional information.
RESPONSE TO COMMENT 3
This information is provided in the Funds statement of additional information.
COMMENT 4 MORE ABOUT OUR INVESTMENT STRATEGIES
Please indicate whether derivatives are a part of the Funds principal investment strategies. If so, please provide the requisite disclosure. See the Commissions concept release, Use of Derivatives by Investment Companies under the Investment Company Act of 1940, Release No. IC-29776 for guidance.
RESPONSE TO COMMENT 4
Derivatives are not a part of the Funds principal investment strategies.
COMMENT 5 GENERAL INFORMATION
As required by Item 12(a)(5) of Form N-1A, please state whether the required information is available through the Funds website at a specified Internet address.
RESPONSE TO COMMENT 5
The Funds prospectus and statement of additional information, both of which are available at www.nuveen.com provide the required information under Item 12(a)(5) of Form N-1A. The following disclosure has been added to the back cover of the prospectus in response to this comment: The best sources for information regarding sales charges and distribution arrangements are the Funds prospectus and statement of additional information. The Fund has chosen to not separately disclose such information on its website because the prospectus and statement of additional information are made available free of charge on the website at www.nuveen.com.
COMMENT 6 GENERAL INFORMATION NET ASSET VALUE
Provide disclosure regarding the calculation of the net asset value upon a shareholders request for redemption.
RESPONSE TO COMMENT 6
In response to this comment, the first sentence of the Net Asset Value section has been revised to read, The price you pay for your shares or the amount you receive upon redemption of your shares is based on your Funds net asset value per share, which is determined as of the close of trading (normally 4:00 p.m. New York time) on each day the NYSE is open for business.
COMMENT 7 GENERAL INFORMATION NET ASSET VALUE
Provide clarify the factors considered when an independent pricing service makes a fair value determination non-U.S. exchange-traded instruments.
RESPONSE TO COMMENT 7
The prospectus has been revised in response to this comment.
STATEMENT OF ADDITIONAL INFORMATION
COMMENT 8 INVESTMENT RESTRICTIONS
In the Investment Restrictions section of the Statement of Additional Information (SAI), please add disclosure to investment restriction number (3) that the limitation will be applicable to municipal bonds if their income is derived from a specific project, in which case the securities are deemed to be from the industry of that project.
RESPONSE TO COMMENT 8
The following disclosure has been added: For purposes of applying the limitation set forth in number 3 above, to the extent that the income from a municipal bond is derived from a specific project, the securities will be deemed to be from the industry of that project.
COMMENT 9 LIMITATIONS ON THE USE OF FUTURES AND FUTURES OPTIONS
Please provide updated language regarding the requirements of CFTC Rule 4.5.
RESPONSE TO COMMENT 9
The statement of additional information has been revised in response to this comment.
COMMENT 10 PORTFOLIO MANAGER
With respect to the portfolio managers cash bonus being influenced by the firms overall profitability, is the bonus based on pre- or post-tax earnings?
RESPONSE TO COMMENT 10
The bonus is based on pre-tax earnings.
TANDY ACKNOWLEDGMENT
In connection with the Trusts registration statement, the Trust acknowledges that;
| should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| the action of the Commission or the staff, acting pursuant to delegated authority in declaring the filing effective, does not relieve the Trust from its full responsibility for the adequacy and accuracy for the disclosure in the filing; and |
| the Trust may 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. |
Please call me at (312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.
Sincerely yours, | ||
CHAPMAN AND CUTLER LLP | ||
By: | /s/ Morrison C. Warren | |
Morrison C. Warren |