0000891804-10-000077.txt : 20110811 0000891804-10-000077.hdr.sgml : 20110811 20100112160921 ACCESSION NUMBER: 0000891804-10-000077 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20100112 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIFTH THIRD FUNDS CENTRAL INDEX KEY: 0000840678 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 38 FOUNTAIN SQUARE PLAZA CITY: CINCINNATI STATE: OH ZIP: 45263 BUSINESS PHONE: 8002825706 MAIL ADDRESS: STREET 1: 38 FOUNTAIN SQUARE PLAZA CITY: CINCINNATI STATE: OH ZIP: 45263 FORMER COMPANY: FORMER CONFORMED NAME: FOUNTAIN SQUARE FUNDS DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.txt [FIFTH THIRD FUNDS LETTERHEAD] January 12, 2010 VIA EDGAR CORRESPONDENCE Ms. Sheila Stout Securities and Exchange Commission Division of Investment Management 100 F. Street, N.E. Washington, DC 20549 Re: Fifth Third Funds ("Registrant") (File Nos. 33-24848 and 811-05669) Dear Ms. Stout: This letter responds to the comments on Form N-SAR for the Registrant on behalf of the Fifth Third Institutional Government Money Market Fund, Fifth Third Institutional Money Market Fund, Fifth Third Prime Money Market Fund and Fifth Third U.S. Treasury Money Market Fund (each, a "Money Market Fund") filed on March 31, 2009 and September 22, 2009 and that were provided by telephone on January 5, 2010. 1. SEC COMMENT: In Form N-SAR, Question 74W requests that the Registrant provide mark-to-market net asset value per share for money market funds only (to four decimals). The Registrant currently has four money market funds. The Fifth Third Institutional Government Money Market Fund, the Fifth Third Institutional Money Market Fund and Fifth Third U.S. Treasury Money Market Fund each has Institutional, Select, Preferred and Trust Shares. The Fifth Third Prime Money Market Fund has Institutional, Class A, Class B and Class C shares. The Commission has requested the Registrant amend each Form N-SAR for each Money Market Fund to include the composite level mark-to-market net asset value per share for each Money Market Fund. RESPONSE: The Registrant left Question 74W blank for each of the Money Market Funds since there were not enough fields to provide mark-to-market net asset value per share for each class of each Fund. The Registrant will amend Question 74W on each Form N-SAR filing to include the composite level mark-to-market per share for each Money Market Fund. The Registrant reviewed Question 74W on Form N-SAR filed on March 28, 2008 and Form N SAR filed on October 3, 2008 for each of the Money Market Funds and confirms that the composite level market-to-market per share for each Money Market Fund was included in the applicable response. If you have any further comments or questions, please contact me at (513) 534-6408. Sincerely, /s/ Matthew A. Swendiman Secretary of the Registrant cc: S. King