0000088053-17-000094.txt : 20170601 0000088053-17-000094.hdr.sgml : 20170601 20170130160632 ACCESSION NUMBER: 0000088053-17-000094 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20170130 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DEUTSCHE SECURITIES TRUST CENTRAL INDEX KEY: 0000088048 IRS NUMBER: 132661231 FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 345 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10154-0004 BUSINESS PHONE: 212-454-6778 MAIL ADDRESS: STREET 1: 345 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10154-0004 FORMER COMPANY: FORMER CONFORMED NAME: DWS SECURITIES TRUST DATE OF NAME CHANGE: 20060207 FORMER COMPANY: FORMER CONFORMED NAME: SCUDDER SECURITIES TRUST DATE OF NAME CHANGE: 19950908 FORMER COMPANY: FORMER CONFORMED NAME: SCUDDER DEVELOPMENT FUND DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DEUTSCHE INTERNATIONAL FUND, INC. CENTRAL INDEX KEY: 0000088053 IRS NUMBER: 132827803 FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 345 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10154-0004 BUSINESS PHONE: 212-454-6778 MAIL ADDRESS: STREET 1: 345 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10154-0004 FORMER COMPANY: FORMER CONFORMED NAME: DWS INTERNATIONAL FUND, INC. DATE OF NAME CHANGE: 20060207 FORMER COMPANY: FORMER CONFORMED NAME: SCUDDER INTERNATIONAL FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: SCUDDER INTERNATIONAL INVESTMENTS LTD DATE OF NAME CHANGE: 19761203 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DEUTSCHE INVESTMENT TRUST CENTRAL INDEX KEY: 0000088064 IRS NUMBER: 042212654 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 345 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10154-0004 BUSINESS PHONE: 212-454-6778 MAIL ADDRESS: STREET 1: 345 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10154-0004 FORMER COMPANY: FORMER CONFORMED NAME: DWS INVESTMENT TRUST DATE OF NAME CHANGE: 20060207 FORMER COMPANY: FORMER CONFORMED NAME: INVESTMENT TRUST DATE OF NAME CHANGE: 19980529 FORMER COMPANY: FORMER CONFORMED NAME: SCUDDER INVESTMENT TRUST DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DEUTSCHE MUNICIPAL TRUST CENTRAL INDEX KEY: 0000203142 IRS NUMBER: 046396607 STATE OF INCORPORATION: MA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 345 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10154-0004 BUSINESS PHONE: 212-454-6778 MAIL ADDRESS: STREET 1: 345 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10154-0004 FORMER COMPANY: FORMER CONFORMED NAME: DWS MUNICIPAL TRUST DATE OF NAME CHANGE: 20060207 FORMER COMPANY: FORMER CONFORMED NAME: SCUDDER MUNICIPAL TRUST DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: SCUDDER MANAGED MUNICIPAL BONDS DATE OF NAME CHANGE: 19880302 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DEUTSCHE INCOME TRUST CENTRAL INDEX KEY: 0000747677 IRS NUMBER: 000000000 FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 345 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10154-0004 BUSINESS PHONE: 212-454-6778 MAIL ADDRESS: STREET 1: 345 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10154-0004 FORMER COMPANY: FORMER CONFORMED NAME: DWS INCOME TRUST DATE OF NAME CHANGE: 20060207 FORMER COMPANY: FORMER CONFORMED NAME: SCUDDER INCOME TRUST DATE OF NAME CHANGE: 20000616 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DEUTSCHE GLOBAL/INTERNATIONAL FUND, INC. CENTRAL INDEX KEY: 0000793597 IRS NUMBER: 000000000 FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 345 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10154-0004 BUSINESS PHONE: 212-454-6778 MAIL ADDRESS: STREET 1: 345 PARK AVENUE CITY: NEW YORK STATE: NY ZIP: 10154-0004 FORMER COMPANY: FORMER CONFORMED NAME: DWS GLOBAL/INTERNATIONAL FUND, INC. DATE OF NAME CHANGE: 20060207 FORMER COMPANY: FORMER CONFORMED NAME: GLOBAL/INTERNATIONAL FUND INC DATE OF NAME CHANGE: 19980605 FORMER COMPANY: FORMER CONFORMED NAME: SCUDDER GLOBAL FUND INC DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm

Deutsche Investment Management Americas Inc.

One Beacon Street

Boston, MA 02108

 

January 30, 2017

 

VIA EDGAR

 

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Alison White

Marianne Dobelbower

 

Re: Deutsche Income Trust (Reg. Nos. 002-91577 and 811-04049) Post-Effective Amendment No. 92 Deutsche International Fund, Inc. (Reg. Nos. 002-14400 and 811-00642) Post-Effective Amendment No. 161 Deutsche Investment Trust (Reg. Nos. 002-13628 and 811-00043) Post-Effective Amendment No. 223 Deutsche Global/International Fund, Inc. (Reg. Nos. 033-05724, 811-04670) Post-Effective Amendment No. 145 Deutsche Municipal Trust (Reg. Nos. 002-57139 and 811-02671) Post-Effective Amendment No. 94 Deutsche Gold & Precious Metals Fund, a series of Deutsche Securities Trust (Reg. Nos. 002-36238 and 811-02021) Post-Effective Amendment No. 166  

 

Dear Ms. White and Ms. Dobelbower,

 

This letter is being submitted on behalf of certain funds in the Deutsche family of funds (herein collectively referred to as the “Funds”) in response to comments of the Staff of the Securities and Exchange Commission (the “SEC”) on the above-captioned Post-Effective Amendments (the “Amendments”), which comments were received via a telephone call on January 4, 2017. These comments were with regard to the addition of Class T shares to the Funds. The Amendments were filed on behalf of the Funds on December 2, 2016, with an effective date of February 1, 2017.

 

The Staff’s comments are restated below followed by the Funds’ responses.

Class T Comments

1.      Comment: To the extent expenses are estimated for Class T, please include a footnote to that effect in each Fund’s expense table. If Class T expenses are estimated, please indicate supplementally why you think that is appropriate.

Response: Each Fund has included a footnote to “Other Expenses” in its expense table that indicates that “other expenses” for Class T are based on estimated amounts for the current fiscal year. Since each Fund’s Class T shares are newly launched and do not have any actual historical class-level expenses, the Funds believe, consistent with Instruction 6(a) to Item 3 of Form N-1A, that it is appropriate to estimate other expenses that would be specific to Class T.

 

2.Comment: To the extent Class T shares appear in a stand-alone prospectus, please be advised that financial highlights for at least one representative existing Fund class must be included in the stand-alone Class T prospectus.

Response: While the Funds’ prospectuses included in the Amendments are not stand-alone Class T prospectuses, we acknowledge and agree that for any Deutsche Fund that is launching Class T shares in a stand-alone prospectus, representative financial highlights for an appropriate existing Fund share class will be included in such stand-alone Class T prospectus.

 

If you have any questions regarding any of the foregoing or require additional information, please call me at (617) 295-3681.

 

Sincerely yours,

 

 

 

/s/ Laura McCollum

 

Laura McCollum

Vice President and Counsel

 

 

 

 

 

cc. John Marten, Esq. Vedder Price