Correspondence 0001580642-25-000178 from BRUCE FUND INC (CIK 0000047071)
BRUCE FUND INC (CIK 0000047071)
Date: Jan. 8, 2025 · CIK: 0000047071 · Accession: 0001580642-25-000178
AI Filing Summary & Sentiment
File numbers found in text: 811-01528
Letter
VIA EDGAR Division of Investment Management, Disclosure Review and Accounting Office 100 F Street, NE Washington, D.C. 20549 Re: Bruce Fund, Inc. (the “Registrant”) File No. 811-01528
Dear Ms. Hamilton:
On behalf of the Registrant, and with respect to the single series of the Registrant (the “Fund”), the following is the Registrant’s response to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on December 4, 2024, with regard to the Registrant’s filing on Form N-CSR for the reporting period ended June 30, 2024 (the “Report”). Each Staff comment is summarized below, followed by the Registrant’s response to the comment.
1. Staff Comment: The Staff notes that the response to Item 10 of Form N-CSR indicates that such disclosure is included within Item 7 of Form N-CSR. Please explain how this satisfies the requirement of Item 10 of Form N-CSR and the Tailored Shareholder Reports Frequently Asked Question #3 requirements.
Registrant’s Response: Registrant will update the financial statements included within Item 7 of Form N-CSR on a going forward basis to include the remuneration paid to directors and officers, consistent with the requirements of Item 10 of Form N-CSR.
2. Staff Comment: The Staff notes that the titles of the individual signing the certifications contained in Form N-CSR do not specifically include “principal executive officer” or “principal financial officer.” Please confirm in correspondence that the individual who signed the certifications is the principal executive officer and principal financial officer. Going forward, please confirm that such titles will be separately included in the signed certifications. See Item 19 of Form N-CSR and General Instructions F, sub-item 2a and 2b.
Registrant’s Response: Registrant confirms that the individual who signed the certifications in the Report and Form N-CSR is the Trust’s principal executive officer and principal financial officer. Registrant also confirms that such titles will be separately
Ms. Lauren Hamilton
January 8, 2025
Page 2
included in such certifications going forward in Form N-CSR and certifications going forward in compliance with General Instructions F, sub-item 2a and 2b.
We trust that these responses are satisfactory to your inquiries. If you have any questions, please contact me at (312)236-9160 or at jbruce22@comcast.net.
Sincerely,
/s/ R. Jeffrey Bruce
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CORRESP 1 filename1.htm BRUCE FUND INC. 20 North Wacker Drive Suite 2414 Chicago, IL 60606 January 8, 2025 VIA EDGAR Ms. Lauren Hamilton U.S. Securities and Exchange Commission Division of Investment Management, Disclosure Review and Accounting Office 100 F Street, NE Washington, D.C. 20549 Re: Bruce Fund, Inc. (the “Registrant”) File No. 811-01528 Dear Ms. Hamilton: On behalf of the Registrant, and with respect to the single series of the Registrant (the “Fund”), the following is the Registrant’s response to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on December 4, 2024, with regard to the Registrant’s filing on Form N-CSR for the reporting period ended June 30, 2024 (the “Report”). Each Staff comment is summarized below, followed by the Registrant’s response to the comment. 1. Staff Comment: The Staff notes that the response to Item 10 of Form N-CSR indicates that such disclosure is included within Item 7 of Form N-CSR. Please explain how this satisfies the requirement of Item 10 of Form N-CSR and the Tailored Shareholder Reports Frequently Asked Question #3 requirements. Registrant’s Response: Registrant will update the financial statements included within Item 7 of Form N-CSR on a going forward basis to include the remuneration paid to directors and officers, consistent with the requirements of Item 10 of Form N-CSR. 2. Staff Comment: The Staff notes that the titles of the individual signing the certifications contained in Form N-CSR do not specifically include “principal executive officer” or “principal financial officer.” Please confirm in correspondence that the individual who signed the certifications is the principal executive officer and principal financial officer. Going forward, please confirm that such titles will be separately included in the signed certifications. See Item 19 of Form N-CSR and General Instructions F, sub-item 2a and 2b. Registrant’s Response: Registrant confirms that the individual who signed the certifications in the Report and Form N-CSR is the Trust’s principal executive officer and principal financial officer. Registrant also confirms that such titles will be separately Ms. Lauren Hamilton January 8, 2025 Page 2 included in such certifications going forward in Form N-CSR and certifications going forward in compliance with General Instructions F, sub-item 2a and 2b. We trust that these responses are satisfactory to your inquiries. If you have any questions, please contact me at (312)236-9160 or at jbruce22@comcast.net. Sincerely, /s/ R. Jeffrey Bruce R. Jeffrey Bruce President and Treasurer Bruce Fund, Inc. Enclosure cc: David S. Klevatt, Esq., Klevatt & Associates, LLC Martin R. Dean, Northern Lights Compliance Services, LLC