|
||
1875 K Street N.W. Washington, DC 20006-1238 Tel: 202 303 1000 Fax: 202 303 2000 |
April 24, 2015
VIA EDGAR
Ms. Kathy Churko
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: | iShares, Inc. (the Company) |
(Securities Act File No. 33-97598 and
Investment Company Act File No. 811-09102)
Dear Ms. Churko:
This letter responds to a comment provided by the staff of the Securities and Exchange Commission (the Staff) with respect to certain financial statements made by the Company, on behalf of certain of its series noted in Appendix A (each a Fund, and together, the Funds). The comment was provided in a telephone conversation on March 25, 2015. For your convenience, the Staffs comment is summarized below and is followed by the Companys response.
Comment: For each of the Funds with a fiscal year end of April 30 or August 31, in the Statements of Operations, the line item Securities lending income affiliated is presented net of fees, as indicated by Note 2 in the Notes to Financial Statements. Please add the word net to the line item to be more clear.
Response: The word net will be added to the identified Statement of Operations line item for all relevant iShares funds beginning with the March 31, 2015 fiscal year ends. The line item will appear as Securities lending income affiliated net.
****
The Company has authorized us to represent on its behalf that, with respect to filings made by the Company with the SEC and reviewed by the Staff, it acknowledges that:
(a) | the Company is responsible for the adequacy and accuracy of the disclosure in the filings; |
(b) | Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the SEC from taking any action with respect to the filings; and |
(c) | the Company may not assert Staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States. |
If you have any questions or need further information, please call me at (202) 303-1124.
Sincerely,
/s/ Benjamin J. Haskin
Benjamin J. Haskin
cc: | Jack Gee |
Mary Miley
Kevin Ryken
Dervilla Lannon
- 2 -
APPENDIX A
iShares, Inc. Series Name |
Fiscal Year End | |
iShares Asia/Pacific Dividend ETF | April 30 | |
iShares Emerging Markets Dividend ETF | April 30 | |
iShares Core MSCI Emerging Markets ETF | August 31 | |
iShares MSCI All Country World Minimum Volatility ETF | August 31 | |
iShares MSCI Australia ETF | August 31 | |
iShares MSCI Austria Capped ETF | August 31 | |
iShares MSCI Belgium Capped ETF | August 31 | |
iShares MSCI Brazil Capped ETF | August 31 | |
iShares MSCI BRIC ETF | August 31 | |
iShares MSCI Canada ETF | August 31 | |
iShares MSCI Chile Capped ETF | August 31 | |
iShares MSCI Colombia Capped ETF | August 31 | |
iShares MSCI Emerging Markets Asia ETF | August 31 | |
iShares MSCI Emerging Markets Consumer Discretionary ETF | August 31 | |
iShares MSCI Emerging Markets Eastern Europe ETF | August 31 | |
iShares MSCI Emerging Markets EMEA ETF | August 31 | |
iShares MSCI Emerging Markets Energy Capped ETF | August 31 | |
iShares MSCI Emerging Markets ETF | August 31 | |
iShares MSCI Emerging Markets Growth ETF | August 31 | |
iShares MSCI Emerging Markets Minimum Volatility ETF | August 31 | |
iShares MSCI Emerging Markets Small-Cap ETF | August 31 | |
iShares MSCI Emerging Markets Value ETF | August 31 | |
iShares MSCI EMU ETF | August 31 | |
iShares MSCI France ETF | August 31 | |
iShares MSCI Frontier 100 ETF | August 31 | |
iShares MSCI Germany ETF | August 31 | |
iShares MSCI Global Agriculture Producers ETF | August 31 | |
iShares MSCI Global Energy Producers ETF | August 31 | |
iShares MSCI Global Gold Miners ETF | August 31 | |
iShares MSCI Global Metals & Mining Producers ETF | August 31 | |
iShares MSCI Global Silver Miners ETF | August 31 | |
iShares MSCI Hong Kong ETF | August 31 | |
iShares MSCI Israel Capped ETF | August 31 | |
iShares MSCI Italy Capped ETF | August 31 | |
iShares MSCI Japan ETF | August 31 | |
iShares MSCI Japan Small-Cap ETF | August 31 | |
iShares MSCI Malaysia ETF | August 31 | |
iShares MSCI Mexico Capped ETF | August 31 |
A-1
iShares MSCI Netherlands ETF |
August 31 | |
iShares MSCI Pacific ex Japan ETF |
August 31 | |
iShares MSCI Singapore ETF |
August 31 | |
iShares MSCI South Africa ETF |
August 31 | |
iShares MSCI South Korea Capped ETF |
August 31 | |
iShares MSCI Spain Capped ETF |
August 31 | |
iShares MSCI Sweden ETF |
August 31 | |
iShares MSCI Switzerland Capped ETF |
August 31 | |
iShares MSCI Taiwan ETF |
August 31 | |
iShares MSCI Thailand Capped ETF |
August 31 | |
iShares MSCI Turkey ETF |
August 31 | |
iShares MSCI United Kingdom ETF (now a series of iShares Trust) |
August 31 | |
iShares MSCI USA ETF |
August 31 | |
iShares MSCI World ETF |
August 31 |
A-2