Correspondence 0001036325-24-000015 from DAVIS NEW YORK VENTURE FUND INC (CIK 0000071701)
DAVIS NEW YORK VENTURE FUND INC (CIK 0000071701)
Date: Feb. 22, 2024 · CIK: 0000071701 · Accession: 0001036325-24-000015
AI Filing Summary & Sentiment
File numbers found in text: 811-01701
Letter
Division of Investment Management – Disclosure Review and Accounting Office Washington DC 20549 Attention: Kim McManus Davis New York Venture Fund, Inc. (40 Act File No.: 811-01701)
Re:
Dear Ms. McManus:
This letter is in response to comments you provided on February 12, 2024, with respect to the 485(a) filing of Davis Global Fund and Davis International Fund, both series of Davis New York Venture Fund, Inc., as identified above. SEC comments are in bold. Registrant’s responses immediately follow.
1.
We request that you respond to these comments no later than five business days before the filing is scheduled to become effective automatically. If this is not possible, we request that you file an amendment under Rule 485(b) delaying effectiveness as needed until Staff comments result.
We confirm that we will respond no later than five business days before the filing is scheduled to become effective automatically.
2.
Please fill in all blanks, brackets, and otherwise missing information sufficiently in advance of effectiveness for review.
We confirm that all blanks, brackets, and otherwise missing information will be filled in in advance of effectiveness for review.
3.
Please unbold the fee and expense paragraph, the example paragraph, and the portfolio turnover paragraph in Item 3 of Form N-1A. With regards to expenses, please provide fees and expenses and the example sufficiently in advance of effectiveness for review.
We have made these changes, and will provide the fees and expenses and the example sufficiently in advance of effectiveness for review.
4.
The new “Shareholder Concentration” risk appears in Item 4 for Davis International Fund but is not included for Davis Global Fund. Correspondence suggests it applies to both funds. Please revise or advise. In addition, please expand Item 9 to identify this risk and clarify if it applies to only one fund.
As of 01/31/2024, the related shareholder holds approximately 12% in Davis Global Fund, which is under the 20% threshold that this risk entails. As shown below, this change has been made to reflect that this risk is for Davis International Fund only.
Shareholder Concentration Risk. (Davis International Fund only) From time to time, a relatively large percentage (over 20%) of the Fund’s shares may be held by related shareholders. A large redemption by one or more of such shareholders may reduce the Fund’s liquidity, may increase the Fund’s transactions and transaction costs, may result in substantial capital gains distributions for shareholders, and may increase the Fund’s ongoing operating expenses, which could negatively impact the remaining shareholders of the Fund.
5.
Please bold the first paragraph following the financial highlights heading consistent with Item 13 of Form N-1A.
We have made this change.
Please call the undersigned at (520) 434-3793 with any comments or questions.
Respectfully,
/s/ Lisa Cohen
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EDGAR CORRESPONDENCE
February 22, 2024
U.S. Securities and Exchange Commission
Division of Investment Management – Disclosure Review and Accounting Office
100 F Street NE
Washington DC 20549
Attention: Kim McManus
Re:
Davis New York Venture Fund, Inc. (40 Act File No.: 811-01701)
Dear Ms. McManus:
This letter is in response to comments you provided on February 12, 2024, with respect to the 485(a) filing of Davis Global Fund and
Davis International Fund, both series of Davis New York Venture Fund, Inc., as identified above. SEC comments are in bold. Registrant’s responses immediately follow.
1.
We request that you respond to these comments no later than five business days before
the filing is scheduled to become effective automatically. If this is not possible, we request that you file an amendment under Rule 485(b) delaying effectiveness as needed until Staff comments result.
We confirm that we will respond no later than five business days before the filing is scheduled to become effective automatically.
2.
Please fill in all blanks, brackets, and otherwise missing information sufficiently in
advance of effectiveness for review.
We confirm that all blanks, brackets, and otherwise missing information will be filled in in advance of effectiveness for review.
3.
Please unbold the fee and expense paragraph, the example paragraph, and the portfolio
turnover paragraph in Item 3 of Form N-1A. With regards to expenses, please provide fees and expenses and the example sufficiently in advance of effectiveness for review.
We have made these changes, and will provide the fees and expenses and the example sufficiently in advance of effectiveness for
review.
4.
The new “Shareholder Concentration” risk appears in Item 4 for Davis International Fund
but is not included for Davis Global Fund. Correspondence suggests it applies to both funds. Please revise or advise. In addition, please expand Item 9 to identify this risk and clarify if it applies to only one fund.
As of 01/31/2024, the related shareholder holds approximately 12% in Davis Global Fund, which is under the 20% threshold that this
risk entails. As shown below, this change has been made to reflect that this risk is for Davis International Fund only.
Shareholder
Concentration Risk. (Davis International Fund only) From time to time, a relatively large percentage (over 20%) of the Fund’s shares may be held by related shareholders. A large redemption by one or more of such shareholders may reduce the
Fund’s liquidity, may increase the Fund’s transactions and transaction costs, may result in substantial capital gains distributions for shareholders, and may increase the Fund’s ongoing operating expenses, which could negatively impact the remaining
shareholders of the Fund.
5.
Please bold the first paragraph following the financial highlights heading consistent
with Item 13 of Form N-1A.
We have made this change.
Please call the undersigned at (520) 434-3793 with any comments or questions.
Respectfully,
/s/ Lisa Cohen
Lisa Cohen
Vice President and Secretary
DAVIS GLOBAL FUND
DAVIS INTERNATIONAL FUND
PROSPECTUS
Portfolios of Davis New York Venture Fund, Inc.
February 29, 2024
Class A
Class C
Class Y
Davis Global Fund
DGFAX
DGFCX
DGFYX
Davis International Fund
DILAX
DILCX
DILYX
The Securities and Exchange Commission has not approved or disapproved these securities or passed upon the
adequacy of this prospectus. Any representation to the contrary is a criminal offense.
Contents
Davis Global Fund Summary
3
Davis International Fund Summary
8
Additional Information About Investment Objectives, Principal Strategies and Principal Risks
13
Additional Information About Expenses, Fees and Performance
16
Non-Principal Investment Strategies and Risks
17
Management and Organization
19
Shareholder Information
20
How Your Shares Are Valued
20
Portfolio Holdings
21
How Davis Funds Pay Earnings
21
Federal Income Taxes
23
Fees and Expenses of the Fund
23
Fees Paid to Dealers and Other Financial Intermediaries
24
How to Choose a Share Class
25
How to Open an Account
30
Anti-Money Laundering Compliance
31
Retirement Plan Accounts
31
How to Buy, Sell and Exchange Shares
32
Buying More Shares
33
Selling Shares
34
Exchanging Shares
37
Frequent Purchases and Redemptions of Fund Shares
37
Telephone Transactions
38
Internet Transactions
38
Householding
39
Financial Highlights
40
Appendix A: Intermediary-Specific Sales Charge Waivers and Discounts
44
This prospectus contains important information. Please read it carefully before investing and keep it for future
reference.
No financial adviser, dealer, salesperson or any other person has been authorized to give any information or to make
any representations, other than those contained in this prospectus, in connection with the offer contained in this prospectus and, if given or made, such other information or representations must not be relied on as having been authorized by the
Funds, the Funds’ investment adviser or the Funds’ distributor.
This prospectus does not constitute an offer by the Funds or by the Funds’ distributor to sell or a solicitation of
an offer to buy any of the securities offered hereby in any jurisdiction to any person to whom it is unlawful for the Funds to make such an offer.
Davis Global Fund Summary
Investment Objective
The Fund seeks long-term growth of capital.
Fees and Expenses of the Fund
These tables describe the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below. You may
qualify for sales charge discounts with respect to Class A shares if you and your family invest, or agree to invest in the future, at least $100,000 in Davis Funds. More information about these and other discounts is available from your financial
intermediary and in “How to Choose a Share Class” on page 25 of the Fund’s prospectus and “Selecting the Appropriate Class of Shares” on page 36 of the Fund’s statement of additional information. In addition, descriptions of the sales load waivers and/or discounts for Class A shares
with respect to certain financial intermediaries are reproduced in “Appendix A: Intermediary-Specific Sales Charge Waivers and Discounts” to the prospectus based on information provided by the financial intermediary.
Shareholder Fees
(fees paid directly from your investment)
Class A shares
Class C shares
Class Y shares
Maximum Sales Charge (Load) Imposed on Purchases
(as a percentage of offering price)
4.75%
None
None
Maximum Deferred Sales Charge (Load)
(as a percentage of the lesser of the net asset value of the shares redeemed or the total cost of such
shares)
0.50%*
1.00%
None
Redemption Fee
(as a percentage of total redemption proceeds)
None
None
None
*
Only applies if you buy shares valued at $1 million or more without a sales charge and sell the shares
within one year of purchase.
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Class A shares
Class C shares
Class Y shares
Management Fees
0.55%
0.55%
0.55%
Distribution and/or Service (12b-1) Fees
0.22%
1.00%
0.00%
Other Expenses
0.18%
0.20%
0.16%
Total Annual Operating Expenses
0.95%
1.75%
0.71%
Less Fee Waiver or Expense Reimbursement*
0.00%
0.00%
0.00%
Net Expenses
0.95%
1.75%
0.71%
*
The Advisers is contractually committed to waive fees and/or reimburse the Fund’s expenses to the extent
necessary to cap total annual fund operating expenses (Class A shares, 1.05%; Class C shares, 1.80%; Class Y shares, 0.80%). The Adviser is obligated to continue the expense cap through March 1, 2025. The expense cap cannot be modified
prior to this date without the consent of the Board of Directors. After that date, there is no assurance that the Adviser will continue to cap expenses. The Adviser may not recoup any of the operating expenses it has reimbursed to the
Fund.
Example. This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The Example assumes
that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain
the same. Although your actual costs may be higher or lower, based on these assumptions, your costs would be:
If you redeem your shares in:
If you did not redeem your shares in:
1 Year
3 Years
5 Years
10 Years
1 Year
3 Years
5 Years
10 Years
Class A shares
$567
$763
$976
$1,586
$567
$763
$976
$1,586
Class C shares
278
551
949
1,851
178
551
949
1,851
Class Y shares
73
227
395
883
73
227
395
883
Portfolio Turnover
The Fund pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher
portfolio turnover rate may indicate higher transaction costs and may result in higher taxes when Fund shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the example, affect the Fund’s
performance. During the most recent fiscal year, the Fund’s portfolio turnover rate was 16% of the average value of its portfolio.
Principal Investment Strategies
Davis Selected Advisers, L.P. (“Davis Advisors” or the “Adviser”), the Fund’s investment adviser, uses the Davis Investment
Discipline to invest Davis Global Fund’s portfolio principally in common stocks (including indirect holdings of common stock through Depositary Receipts, as defined below) issued by both United States and foreign companies, including countries with
developed or emerging markets. The Fund may invest in large, medium or small companies without regard to market capitalization. The Fund will invest significantly (at least 40% of total assets under normal market conditions and at least 30% of
total assets if market conditions are not deemed favorable) in issuers (1) organized or located outside of the U.S.; (2) whose primary trading market is located outside the U.S.; or (3) doing a substantial amount of business outside the U.S., which
the Fund considers to be a company that derives at least 50% of its revenue from business outside the U.S. or has at least 50% of its assets outside the U.S. Under normal market conditions, the Fund will invest in issuers representing at least
three different countries. These non-U.S. company investments may include American Depositary Receipts (“ADRs”) and Global Depositary Receipts (“GDRs” and together “Depositary Receipts”). Depositary Receipts are receipts that represent ownership of
shares of a non-U.S. issuer held in trust by a bank or similar financial institution.
Davis Investment
Discipline. Davis Advisors manages equity funds using the Davis Investment Discipline. Davis Advisors conducts extensive research to try to identify businesses that possess characteristics that Davis Advisors believes foster the creation
of long-term value, such as proven management, a durable franchise and business model, and sustainable competitive advantages. Davis Advisors aims to invest in such businesses when they are trading at discounts to their intrinsic worth. Davis
Advisors emphasizes individual stock selection and believes that the ability to evaluate management is critical. Davis Advisors routinely visits managers at their places of business in order to gain insight into the relative value of different
businesses. Such research, however rigorous, involves predictions and forecasts that are inherently uncertain. After determining which companies Davis Advisors believes the Fund should own, Davis Advisors then turns its analysis to determining the
intrinsic value of those companies’ equity securities. Davis Advisors seeks companies whose equity securities can be purchased at a discount from Davis Advisors’ estimate of the company’s intrinsic value based upon fundamental analysis of cash
flows, assets and liabilities, and other criteria that Davis Advisors deems to be material on a company-by-company basis. Davis Advisors’ goal is to invest in companies for the long term (ideally, five years or longer, although this goal may not be
met). Davis Advisors considers selling a company’s equity securities if the securities’ market price exceeds Davis Advisors’ estimates of intrinsic value, if the ratio of the risks and rewards of continuing to own the company’s equity securities is
no longer attractive, to raise cash to purchase a more attractive investment opportunity, to satisfy net redemptions, or for other purposes.
Principal Risks of Investing in Davis Global Fund
You may lose money by investing in the Fund. Investo