SEC Company Response from AB BOND FUND, INC. (CIK 0000003794) — Mar 27, 2020
AB BOND FUND, INC. (CIK 0000003794)
Date: March 27, 2020 · CIK: 0000003794 · Accession: 0000919574-20-002599
AI Filing Summary & Sentiment
File numbers found in text: 811-00126, 811-00134, 811-01716, 811-05398, 811-06068, 811-07618, 811-07707, 811-07916, 811-09687, 811-10221, 811-21497
Letter
VIA EDGAR CORRESPONDENCE Division of Investment Management 200 Vesey Street – Suite 400 New York, NY 10281-1022 Attention: Mindy Rotter Re: In the matter of the SEC Filings set forth in Appendix B hereto
Dear Ms. Rotter:
Attached as Appendix A are responses to the comments made during your phone conversation with Phyllis Clarke and other representatives of AllianceBernstein L.P. on February 27, 2020.
If you have any questions regarding our response, please do not hesitate to call me at 914.259.7740.
Sincerely,
/s/ Joseph Mantineo
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CORRESP
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filename1.htm
AB Funds
1345 Avenue of the Americas
New York, NY 10105
March 27, 2020
VIA EDGAR CORRESPONDENCE
Division of Investment Management
Disclosure Review and Accounting Office
U.S. Securities and Exchange Commission
Brookfield Place
200 Vesey Street – Suite 400
New York, NY 10281-1022
Attention: Mindy Rotter
Re: In the matter of the SEC Filings set forth in Appendix B hereto
Dear Ms. Rotter:
Attached as Appendix A are responses to the comments made during
your phone conversation with Phyllis Clarke and other representatives of AllianceBernstein L.P. on February 27, 2020.
If you have any questions regarding our response, please do not
hesitate to call me at 914.259.7740.
Sincerely,
/s/ Joseph Mantineo
Joseph Mantineo
Treasurer and Chief Financial
Officer of each Fund
cc: Michael Reyes, Senior Analyst of the Funds
Mark R. Manley, AllianceBernstein L.P.
Emilie Wrapp, AllianceBernstein L.P.
Eric Freed, AllianceBernstein L.P.
Vince Noto, AllianceBernstein L.P
Steve Woetzel, AllianceBernstein L.P.
Phyllis Clarke, AllianceBernstein L.P.
Appendix A
Comment #1:
Various Funds
The funds did not use the current version
of Form N-CSR. For future filings, please use the current version of the form that can be found on the SEC's website. (It
is not necessary to refile previously filed reports as the updates to the form pertain to closed-end funds.)
Response #1: The Funds will use the current
version of Form N-CSR for all future filings.
Comment #2:
Funds #: 1- 3, 5-11, 35-43, 45-47 &
69-85
Please confirm in correspondence that there
were no open payables to directors at year-end; if there were, these payables should be disclosed separately on the Statement of
Assets and Liabilities in accordance with Rule 6-04 of Regulation S-X.
Response #2: It is the Adviser's policy
to disclose open payables to directors separately on the Statement of Assets and Liabilities in accordance with Rule 6-04 of Regulation
S-X. In the case of the annual reports noted by the Staff, funds 71-85 had such payables that were not separately disclosed. The
annual reports for the other referenced funds separately disclosed such payables. The Adviser will ensure the cited guidance is
applied to all funds in the future.
Comment #3:
Funds #: 3, 6-8, 11, 14, 18, 20-21,
23-29, 32, 36, 42, 45, 53, 57-59, 66, 68, 72 & 77
Please confirm that there are no components
of accrued expenses and other liabilities that should appear separately on the Statement of Assets and Liabilities. For the referenced
funds, certain amounts appear to represent greater than 5%.
Response #3: It is the Adviser's policy
to disclose separately any components of accrued expenses and other liabilities that are greater than 5% of the total liabilities
on the Statement of Assets and Liabilities. In the case of the annual reports noted by the Staff, funds 6, 7, 8 & 29 had such
components that were not separately disclosed. No component of accrued expenses and other liabilities exceeded 5% for the other
referenced funds. The Adviser will ensure that components exceeding 5% are disclosed for all funds in the future.
Comment #4:
Funds #: 3, 6-8 & 10
Miscellaneous expenses as presented in
the Statements of Operations for the referenced funds exceed 5% of total expenses. Please confirm that any categories of miscellaneous
expenses have been separately identified to the extent required by Rule 6-07(2)(b) of Regulation S-X.
Response #4: It is the Adviser's policy
to disclose miscellaneous expenses in the Statement of Operations in accordance with Rule 6-07(2)(b) of Regulation S-X. In the
case of the annual reports noted by the Staff, funds 6, 7, 8 and 10 had categories of expenses exceeding 5% of total expenses that
were not separately disclosed. No component of miscellaneous expenses exceeded 5% for fund 3. The Adviser will ensure that the
cited guidance is applied to all funds in the future.
Comment #5:
Fund #: 35
Please consider adding disclosure to the
Notes to the Financial Statements stating that the distributions received from real estate investment trusts (REITs) may be classified
as dividends, capital gains, and/or returns of capital.
Response #5: The Registrant has determined
to add the recommended disclosure to this fund’s future shareholder reports.
Comment #6:
Funds #: 11, 37-51, 53-66, 69,70, 72,
75 & 80-85
The referenced funds disclosed that management
was still evaluating the impact of Accounting Standards Update 2017-08 - Receivables - Nonrefundable Fees and Costs (Subtopic 310-20),
Premium Amortization on Purchased Callable Debt Securities. This ASU became effective for fiscal years (and interim periods
within fiscal years) beginning after December 15, 2018. Accordingly, please explain in correspondence why management is still
evaluating the impact.
Response #6: The referenced funds were
not yet required to disclose the impact of the implementation in the reports reviewed. As noted, the ASU became effective
for fiscal years beginning after December 15, 2018, and all of the reports reviewed were for periods beginning prior to that date.
Comment #7:
Fund #: 48
Please explain the significant increase
in the portfolio turnover rate in comparison to the prior year, as presented in the referenced fund’s Financial Highlights.
Response #7: During the fiscal year,
the referenced fund’s portfolio managers identified and traded based on certain opportunities that they believed
existed in the markets. The fund’s portfolio turnover rate for the six-month period ended October 31, 2019
(unannualized) returned to the more typical level of approximately 25%.
Comment #8:
Fund #: 1
Please explain in correspondence how the
amount disclosed for expenses net of waivers/reimbursements for Class B shares, as presented in the referenced fund’s Financial
Highlights, was derived.
Response #8: The gross expense ratio on Class B shares is 1.88%.
This ratio is reduced by a voluntary fee waiver by the distributor of .60% and a contractual fee waiver by the Adviser of .02%
due to the fund’s investment in an affiliated fund. This results in the reported net expense ratio of 1.26% disclosed
in the fund’s Financial Highlights. Pursuant to SEC regulations, the voluntary fee waiver was not reflected in the referenced
fund’s prospectus fee table.
Comment #9:
Fund #: 37
Please explain the difference between the
net assets at end of period as presented in the Statement of Assets and Liabilities versus that presented in the Financial Highlights.
Response #9: The difference in net assets
was due to adjustments made on the Statement of Assets and Liabilities that were not flowed through to the Financial Highlights.
(The Fund will reflect such adjustments in the Financial Highlights included in the semi-annual report for the period ending June
30, 2020.)
Comment #10:
Fund #: 5
Please explain why the expense ratios of
1.84%, 2.71% and 1.64% (for Class A, Class C and Adviser Class shares respectively) in the Management’s Discussion of Fund
Performance do not agree with the percentages noted in the referenced fund’s February 28, 2018 prospectus.
Response #10: The referenced fund’s
prospectus was supplemented on June 14, 2018 to correct errors in the fee table in the February 28, 2018 prospectus that had the
effect of overstating the net expense ratios of the fund. The gross expense ratios in the Management’s Discussion of Fund
Performance match those in the prospectus as supplemented.
Comment #11:
Fund #: 70
The referenced fund’s prospectus
applicable at the time of this filing and its website note that the minimum initial investment in the fund is $3,000,000. Please
explain in correspondence why the line graph is not based on this amount in accordance with the instructions to Item 27(b)(7)(ii)(A)
of Form N-1A.
Response #11: The Adviser will use the
minimum investment of $3,000,000 in the line graphs in the fund’s shareholder reports going forward.
Comment #12:
Fund #: 27
The staff noted that the registrant responded
“Yes” to Item C.6.b of Form N-CEN (regarding securities lending), but responded “N/A” to Item C.6.f. Please
confirm the accuracy of these responses; if a response is incorrect, please provide the required information and consider filing
an amended Form N-CEN including this information.
Response #12: The Registrant had only one day of securities lending
activity during the fiscal year, and the weighted average value of securities on loan rounded to 0.00. In the past, the Adviser
had received a suspension notification from EDGAR for attempting to file with a numeric zero and therefore changed the answer to
"N/A" to avoid future suspensions. The Adviser has since confirmed with EDGAR filer support that “0.00” is
a valid dollar value and will be filing as such in future filings where applicable.
Appendix B
Fund #
File #
Registrant Name
Series ID
Series Name
FYE Reviewed
1
811-09687
AB CORE OPPORTUNITIES FUND, INC.
S000009999
AB CORE OPPORTUNITIES FUND, INC.
11/30/2018
2
811-07916
AB EQUITY INCOME FUND INC
S000010125
AB EQUITY INCOME FUND INC
11/30/2018
3
811-01716
AB CAP FUND, INC.
S000062452
AB ALL CHINA EQUITY PORTFOLIO
11/30/2018
4
811-01716
AB CAP FUND, INC.
S000045542
AB Small Cap Value Portfolio
11/30/2018
5
811-01716
AB CAP FUND, INC.
S000047072
AB All Market Income Portfolio
11/30/2018
6
811-01716
AB CAP FUND, INC.
S000045181
AB FlexFee Emerging Markets Growth Portfolio
12/31/2018
7
811-01716
AB CAP FUND, INC.
S000056730
AB FlexFee Core Opportunities Portfolio
12/31/2018
8
811-01716
AB CAP FUND, INC.
S000056731
AB FlexFee International Strategic Core Portfolio
12/31/2018
9
811-01716
AB CAP FUND, INC.
S000056728
AB FlexFee Large Cap Growth Portfolio
12/31/2018
10
811-01716
AB CAP FUND, INC.
S000056729
AB FlexFee US Thematic Portfolio
12/31/2018
11
811-01716
AB CAP FUND, INC.
S000033729
AB Emerging Markets Multi-Asset Portfolio
3/31/2019
12
811-01716
AB CAP FUND, INC.
S000034947
AB Select US Equity Portfolio
6/30/2019
13
811-01716
AB CAP FUND, INC.
S000039195
AB Select US Long/Short Portfolio
6/30/2019
14
811-01716
AB CAP FUND, INC.
S000043215
AB Concentrated Growth Fund
6/30/2019
15
811-01716
AB CAP FUND, INC.
S000045541
AB Concentrated International Growth Portfolio
6/30/2019
16
811-01716
AB CAP FUND, INC.
S000050223
AB International Strategic Core Portfolio
6/30/2019
17
811-01716
AB CAP FUND, INC.
S000047073
AB Global Core Equity Portfolio
6/30/2019
18
811-01716
AB CAP FUND, INC.
S000047115
AB Multi-Manager Select 2010 Fund
7/31/2019
19
811-01716
AB CAP FUND, INC.
S000047116
AB Multi-Manager Select 2055 Fund
7/31/2019
20
811-01716
AB CAP FUND, INC.
S000047117
AB Multi-Manager Select Retirement Allocation Fund
7/31/2019
21
811-01716
AB CAP FUND, INC.
S000047118
AB Multi-Manager Select 2015 Fund
7/31/2019
22
811-01716
AB CAP FUND, INC.
S000047119
AB Multi-Manager Select 2020 Fund
7/31/2019
23
811-01716
AB CAP FUND, INC.
S000047120
AB Multi-Manager Select 2025 Fund
7/31/2019
24
811-01716
AB CAP FUND, INC.
S000047121
AB Multi-Manager Select 2030 Fund
7/31/2019
25
811-01716
AB CAP FUND, INC.
S000047122
AB Multi-Manager Select 2035 Fund
7/31/2019
26
811-01716
AB CAP FUND, INC.
S000047123
AB Multi-Manager Select 2040 Fund
7/31/2019
27
811-01716
AB CAP FUND, INC.
S000047124
AB Multi-Manager Select 2045 Fund
7/31/2019
28
811-01716
AB CAP FUND, INC.
S000047125
AB Multi-Manager Select 2050 Fund
7/31/2019
29
811-01716
AB CAP FUND, INC.
S000064761
AB Multi-Manager Select 2060 Fund
7/31/2019
30
811-01716
AB CAP FUND, INC.
S000010309
AB Small Cap Growth Portfolio
7/31/2019
Fund #
File #
Registrant Name
Series ID
Series Name
FYE Reviewed
31
811-00126
AB RELATIVE VALUE FUND, INC.
S000010080
AB RELATIVE VALUE FUND, INC.
10/31/2018
32
811-10221
AB TRUST
S000010411
AB Value Fund
11/30/2018
33
811-10221
AB TRUST
S000010412
AB Discovery Value Fund
11/30/2018
34
811-10221
AB TRUST
S000010413
AB International Value Fund
11/30/2018
35
811-07707
AB GLOBAL REAL ESTATE INVESTMENT FUND INC
S000010124
AB GLOBAL REAL ESTATE INVESTMENT FUND, INC.
11/30/2018
36
811-00134
AB GLOBAL RISK ALLOCATION FUND, INC.
S000009974
AB GLOBAL RISK ALLOCATION FUND, INC.
11/30/2018
37
811-05398
AB VARIABLE PRODUCTS SERIES FUND, INC.
S000010429
AB International Growth Portfolio
12/31/2018
38
811-05398
AB VARIABLE PRODUCTS SERIES FUND, INC.
S000010431
AB International Value Portfolio
12/31/2018
39
811-05398
AB VARIABLE PRODUCTS SERIES FUND, INC.
S000010432
AB Large Cap Growth Portfolio
12/31/2018
40
811-05398
AB VARIABLE PRODUCTS SERIES FUND, INC.
S000010435
AB Small Cap Growth Portfolio
12/31/2018
41
811-05398
AB VARIABLE PRODUCTS SERIES FUND, INC.
S000010436
AB Small/Mid Cap Value Portfolio
12/31/2018
42
811-05398
AB VARIABLE PRODUCTS SERIES FUND, INC.
S000010437
AB Intermediate Bond Portfolio
12/31/2018
43
811-05398
AB VARIABLE PRODUCTS SERIES FUND, INC.
S000010443
AB Balanced Wealth Strategy Portfolio
12/31/2018
44
811-05398
AB VARIABLE PRODUCTS SERIES FUND, INC.
S000010447
AB Global Thematic Growth Portfolio
12/31/2018
45
811-05398
AB VARIABLE PRODUCTS SERIES FUND, INC.
S000010448
AB Growth and Income Portfolio
12/31/2018
46
811-05398
AB VARIABLE PRODUCTS SERIES FUND, INC.
S000031722
AB Dynamic Asset Allocation Portfolio
12/31/2018
47
811-05398
AB VARIABLE PRODUCTS SERIES FUND, INC.
S000049082
AB Global Risk Allocation-Moderate Portfolio
12/31/2018
48
811-21497
AB CORPORATE SHARES
S000010876
AB CORPORATE INCOME SHARES
4/30/2019
49
811-21497
AB CORPORATE SHARES
S000029560
AB Municipal Income Shares
4/30/2019
50
811-21497
AB CORPORATE SHARES
S000029838
AB Taxable Multi-Sector Income Shares
4/30/2019
Fund #
File #
Registrant Name
Series ID
Series Name
FYE Reviewed
51
811-21497
AB CORPORATE SHARES
S000058704
AB Impact Municipal Income Shares
4/30/2019
52
811-06068
AB FIXED INCOME SHARES INC
S000011990
AB Government Money Market Portfolio
4/30/2019
53
811-07618
AB MUNICIPAL INCOME FUND II
S000010353
AB Arizona Portfolio
5/31/2019
54
811-07618
AB MUNICIPAL INCOME FUND II
S000010355
AB Massachusetts Portfolio
5/31/2019
55
811-07618
AB MUNICIPAL INCOME FUND II
S000010357
AB Minnesota Portfolio
5/31/2019
56
811-07618
AB MUNICIPAL INCOME FUND II
S000010358
AB New Jersey Portfolio
5/31/2019
57
811-07618
AB MUNICIPAL INCOME FUND II
S000010359
AB Ohio Portfolio
5/31/2019
58
811-07618
AB MUNICIPAL INCOME FUND II
S000010360
AB Pennsylvania Portfolio
5/31/2019
59
811-07618
AB MUNICI