0001144204-10-039711.txt : 20120625
0001144204-10-039711.hdr.sgml : 20120625
20100728111610
ACCESSION NUMBER: 0001144204-10-039711
CONFORMED SUBMISSION TYPE: CORRESP
PUBLIC DOCUMENT COUNT: 1
FILED AS OF DATE: 20100728
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: TOUCHSTONE FUNDS GROUP TRUST
CENTRAL INDEX KEY: 0000914243
IRS NUMBER: 680325521
STATE OF INCORPORATION: DE
FISCAL YEAR END: 0930
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 303 BROADWAY
STREET 2: SUITE 1100
CITY: CINCINNATI
STATE: OH
ZIP: 45202
BUSINESS PHONE: 5133628000
MAIL ADDRESS:
STREET 1: 303 BROADWAY
STREET 2: SUITE 1100
CITY: CINCINNATI
STATE: OH
ZIP: 45202
FORMER COMPANY:
FORMER CONFORMED NAME: CONSTELLATION FUNDS
DATE OF NAME CHANGE: 20040412
FORMER COMPANY:
FORMER CONFORMED NAME: ALPHA SELECT FUNDS
DATE OF NAME CHANGE: 19981216
FORMER COMPANY:
FORMER CONFORMED NAME: TIP INSTITUTIONAL FUNDS
DATE OF NAME CHANGE: 19971205
CORRESP
1
filename1.txt
July 28, 2010
Mr. John Ganley
Division of Investment Management
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Touchstone Funds Group Trust
File Nos. 811-08104 and 333-165902
Dear Mr. Ganley:
This will confirm our telephone conversation on Wednesday July 28, 2010
regarding the N-14 filing made by the Touchstone Funds Group Trust
("Registrant") on July 27, 2010. Your comments and the Registrant's responses
are set forth below:
PROSPECTUSES
Comment
In the Q&A section of the prospectus/proxy statement, under the question "How
will the fees compare?" you asked that we revise the last sentence to state the
following:
However, Touchstone Funds Group Trust and Touchstone Advisors, Inc. have entered
into an expense limitation agreement whereby Mazama Growth's total operating
expenses (excluding dividend expenses relating to short sales, interest, taxes,
brokerage commissions, other expenditures which are capitalized in accordance
with generally accepted accounting principles, the cost of "Acquired Fund Fees
and Expenses," if any, other extraordinary expenses not incurred in the ordinary
course of Touchstone's business, and amounts, if any, payable pursuant to a plan
adopted in accordance with Rule 12b-1 under the 1940 Act) will be contractually
limited to 0.98% until at least January 27, 2014.
Response
The requested change has been made.
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Comment
In the Summary section on page 1 of the prospectus/proxy statement, under the
heading "Why is the Reorganization being proposed?" you asked that we include
the following sentence after the sentence that begins with "Furthermore":
The elimination of the unified fee structure will result in higher gross
expenses after the Reorganization.
Response
The requested change has been made.
In connection with this filing, the Trust acknowledges that: (1) the Trust is
responsible for the adequacy and accuracy of the disclosure in the filing; (2)
staff comments or changes to disclosure in connection with this filing, reviewed
by the staff do not foreclose the Commission from taking any action with respect
to the filing; and (3) the Trust may not assert staff comments as a defense in
any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
Please contact the undersigned at 513-878-4066 if you have any questions or need
any additional information.
Very truly yours,
/s/ Jay S. Fitton
Jay S. Fitton
Secretary
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