0000088053-11-000273.txt : 20111020 0000088053-11-000273.hdr.sgml : 20111020 20110224160127 ACCESSION NUMBER: 0000088053-11-000273 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20110224 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DWS MARKET TRUST CENTRAL INDEX KEY: 0000095603 IRS NUMBER: 366103490 STATE OF INCORPORATION: MA FISCAL YEAR END: 1031 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 BALANCED FUND DATE OF NAME CHANGE: 20060207 FORMER COMPANY: FORMER CONFORMED NAME: SCUDDER TOTAL RETURN FUND DATE OF NAME CHANGE: 20010614 FORMER COMPANY: FORMER CONFORMED NAME: KEMPER TOTAL RETURN FUND DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm co022411_mkt.htm
Deutsche Investment Management Americas Inc.
One Beacon Street
Boston, MA 02108


February 24, 2011

VIA EDGAR
Mr. Kieran G. Brown
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

Re:
Post-Effective Amendment No. 77 to the Registration Statement on Form N-1A of DWS Balanced Fund (the “Fund”) (Reg. Nos. 002-21789 and 811-01236)

 
Dear Mr. Brown,
 
This letter is being submitted to respond to the comments of the Staff of the Securities and Exchange Commission (“SEC”) received via a telephone conference call on February 14, 2011 relating to the above-captioned Post-Effective Amendment filed with the SEC on December 30, 2010.
 
The Staff’s comments are restated below, followed by the Fund’s responses.
 
General Comments

1.  General

Comment:  Confirm that applicable general comments recently received from the Staff in correspondence filed with the SEC on [date] and [date] will be incorporated in the Fund’s Registration Statement.
 
Response: Applicable changes will be reflected in the Fund’s Registration Statement.
 
Fund Specific Comments

2.  DWS Balanced Fund

a.  
Comment:  The Staff takes the position that a fund with “Balanced” in its name must invest at least 25% of its assets in equity securities. Please add appropriate disclosure.
 
Response:  Appropriate disclosure has been added.
 
b.  
Comment:  The first sentence in the Fund’s “Small company risk” section states that “Small company stocks tend to be more volatile than large company stocks.” Consider adding disclosure that small company stocks are also more volatile than “medium company stocks.”
 
Response:  Appropriate disclosure has been added.
 
 
 
 
 
 
c.  
Comment:  Given the Fund’s current size consider eliminating or modifying the sentence in the Fund’s IPO risk disclosure that states “IPOs can have more impact on the performance of a small mutual fund because the number of IPO shares the fund is able to buy may represent a significant portion of its overall portfolio compared to the portfolio of a larger fund.”
 
Response: The Fund’s IPO risk disclosure has been appropriately modified.
 
d.  
Comment:  Performance section is missing a description of the Fund’s additional index.
 
Response:  Appropriate disclosure has been added.
 

 
If you have any questions regarding the foregoing or need more additional information, please do not hesitate to call me at (617) 295-3357.
 
Very truly yours,
 
 /s/Thomas H. Connors
Thomas H. Connors
Director and Senior Counsel

cc.           John Marten, Vedder Price P.C.