0001144204-10-060181.txt : 20120625
0001144204-10-060181.hdr.sgml : 20120625
20101115090016
ACCESSION NUMBER: 0001144204-10-060181
CONFORMED SUBMISSION TYPE: CORRESP
PUBLIC DOCUMENT COUNT: 1
FILED AS OF DATE: 20101115
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
November 15, 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. 33-70958 and 811-8104
Dear Mr. Ganley:
This will confirm our telephone conversation regarding the 485(a) filing made by
the Touchstone Funds Group Trust ("Registrant") on September 14, 2010. Your
comments and the Registrant's responses are set forth below:
PROSPECTUSES
Comment
Under the section "The Fund's Fees and Expenses," you asked that we provide the
page number of the sections referenced in the prospectus and statement of
additional information.
Response
We believe referencing the section names is sufficient information for the
shareholder since these sections will be included in the corresponding
document's table of contents.
Comment
In regards to the fee table footnotes, you requested that we move the following
sentence in footnote number 2 to a separate, stand alone footnote.
"Other Expenses" are based on estimated amounts for the current fiscal year.
Response
The requested change has been made.
Comment
You suggested that we add headings to the risks discussed in the section titled
"The Principal Risks" for the Fund.
Response
The Registrant believes that the risks are written in a concise, clear manner
and that further streamlining may make such disclosure less useful to the
reader.
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Comment
You suggested that we include a phrase under the section "What are the Principal
Risks of Investing in the Fund" that clarifies that this is information
regarding some of the principal risks of the Fund.
Response
The requested change has been made.
Comment
You suggested that we move "Manager of Managers Risk" from the section "What are
the Principal Risks of Investing in the Fund" to the section "What are some of
the Non-Principal Risks of Investing in the fund."
Response
The requested change has been made.
Comment
In reference to the "Portfolio Manger" section, you asked why the other team
members that are led by Frank Sands Jr. were not listed as Portfolio Managers.
Response
The sub-advisor has determined that Frank Sands Jr. is the only primary
Portfolio Manager of the fund. The sub-advisor believes that the team members
that work with Mr. Sands Jr. are acting in a supporting role and providing
research analysis for the investment decisions of Mr. Sands Jr.
SAI
Comment
You asked that we consider changing the word "Supplemented" with "Amended" when
referencing the revised date on the front cover of the SAI.
Response
The requested change has been made.
Comment
You asked that we consider putting the other accounts managed information of the
portfolio managers in table format.
Response
We will consider this change for the Annual update in January 2011.
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Comment
In reference to the section titled "Disclosure of Portfolio Holdings," you
suggested that we add language to specify why we would grant access of the
holdings to the sub-advisor.
Response
We will consider this change for the Annual update in January 2011.
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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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