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SEC Company Response from SELECTED INTERNATIONAL FUND, INC (CIK 0000084237) — Apr 17, 2020

SELECTED INTERNATIONAL FUND, INC (CIK 0000084237)
Date: April 17, 2020 · CIK: 0000084237 · Accession: 0000084237-20-000007

AI Filing Summary & Sentiment

Date
April 17, 2020
Author
/s/ Ryan Charles
Form
CORRESP
Company
SELECTED INTERNATIONAL FUND, INC (CIK 0000084237)

Letter

Division of Investment Management Washington, DC 20549 Selected American Shares, Inc. File Nos.: 811‑51, 002‑10699 Selected International Fund, Inc. File Nos.: 811‑01533, 002‑27514

RE:

Dear Ms. Lithotomos:

This letter is on behalf of Selected American Shares, Inc. and Selected International Fund, Inc. (the “Selected Funds”). This letter provides a response on behalf of Selected Funds to your comments received during our phone call on April 13, 2020.

For your convenience, SEC comments are in bold type and the Registrant’s response immediately follows.

1.

Confirm that, with respect to Selected American Shares, no more than 20% of net assets are to be invested in equities given the reference to “Shares” in the Fund’s name.

We confirm that more than 80% of assets for Selected American Shares will be invested in equities. As of 4/14/2020 the Fund had 95.03% invested in equities.

2.

Confirm that, with respect to Selected American Shares, no more than 20% of net assets are to be invested in non-American securities given the reference to “American” in the Fund’s name.

We confirm that no more than 20% of assets for Selected American Shares will be invested in non-American equities. As of 4/14/2020 the Fund had 17.24% of assets invested in non-American equities.

3.

Consider whether the Funds should disclose Cybersecurity Risk as a principal risk.

We have considered the addition of Cybersecurity Risk to the statutory risks, but have determined that it is not a principal risk and that placement within the statement of additional information remains appropriate.

4.

Significant market events have occurred since this post-effective amendment was filed as a result of the COVID-19 pandemic. Please consider whether the Portfolios’ disclosures, including risk disclosures, should be revised based on how these events are affecting both debt and equity markets. If the Registrant believes that no additional disclosure is warranted, please explain why not.

The following additional disclosure has been added to the discussion of stock market risk:

As an example, the rapid and global spread of a highly contagious novel coronavirus respiratory disease, COVID-19, has resulted in extreme volatility in the financial markets and severe losses; reduced liquidity of many instruments; significant disruptions to business operations (including business closures); disruptions to supply chains, consumer demand and employee availability; and widespread uncertainty regarding the duration and long-term effects of this pandemic. Some sectors of the economy and individual issuers have experienced particularly large losses. In addition, the COVID-19 pandemic may result in a sustained economic downturn or a global recession. The ultimate economic fallout from the pandemic, and the long-term impact on economies, markets, industries and individual issuers, are not known. The COVID-19 pandemic could adversely affect the value and liquidity of a fund’s investments, impair a fund’s ability to satisfy redemption requests, and negatively impact fund performance. In addition, the outbreak of COVID-19, and measures taken to mitigate its effects, could result in disruptions to the services provided to the fund by its service providers.

5.

In the Portfolio Manager disclosure, please include the month and year that the Portfolio Manager joined the investment manager.

We confirm that this update has been made.

6.

In the statement of additional information, in the section regarding concentration, please revise the language to read, “engaged in any particular industry or group of industries.”

We confirm that this update has been made.

7.

We note that the registration statement includes language limiting the Funds to investing up to 25% of assets in a particular industry or group of industries. We also note disclosure regarding an internal trigger of 5% to 10% for those investment types that are considered non-principal investment strategies. However, in this section, it indicates that there are exceptions to this 5% to 10% trigger (including industry concentrations). Please explain further.

Upon review, we have determined that as no exceptions exist and to avoid any confusion, it is appropriate to remove the following sentence. There are exceptions to the 5% to 10% of assets test, including, but not limited to, the percentage of a Fund’s assets invested in a single industry or in a single country.

8.

In the Director table, please add, “during the past five years” as noted in the instructions to Form N-1A.

We confirm that this update has been made.

We would be happy to provide you with any additional information you may require or with copies of any of the materials referred to above. Please direct any communications relating to this filing to:

Ryan Charles

Davis Selected Advisers, L.P.

2949 E. Elvira Road, Suite 101

Tucson, AZ 85756

520-434-3778

Sincerely,
/s/ Ryan Charles

Show Raw Text
CORRESP
1
filename1.htm

    April 17, 2020

    Via Electronic Transmission

    Division of Investment Management

    U.S. Securities and Exchange Commission

    100 F Street NE

    Washington, DC 20549

              RE:

                Selected American Shares, Inc. File Nos.: 811‑51, 002‑10699

    Selected International Fund, Inc. File Nos.: 811‑01533, 002‑27514

    Dear Ms. Lithotomos:

    This letter is on behalf of Selected American Shares, Inc. and Selected International Fund, Inc. (the “Selected Funds”). This letter
      provides a response on behalf of Selected Funds to your comments received during our phone call on April 13, 2020.

    For your convenience, SEC comments are in bold type and the Registrant’s response immediately follows.

              1.

              Confirm that, with respect to Selected American Shares, no more than 20% of net assets are to be invested
                in equities given the reference to “Shares” in the Fund’s name.

    We confirm that more than 80% of assets for Selected American Shares will be invested in equities. As of 4/14/2020 the Fund had 95.03%
      invested in equities.

              2.

              Confirm that, with respect to Selected American Shares, no more than 20% of net assets are to be invested
                in non-American securities given the reference to “American” in the Fund’s name.

    We confirm that no more than 20% of assets for Selected American Shares will be invested in non-American equities. As of 4/14/2020 the
      Fund had 17.24% of assets invested in non-American equities.

              3.

              Consider whether the Funds should disclose Cybersecurity Risk as a principal risk.

    We have considered the addition of Cybersecurity Risk to the statutory risks, but have determined that it is not a principal risk and
      that placement within the statement of additional information remains appropriate.

              4.

              Significant market events have occurred since this post-effective amendment was filed as a result of the
                COVID-19 pandemic. Please consider whether the Portfolios’ disclosures, including risk disclosures, should be revised based on how these events are affecting both debt and equity markets. If the Registrant believes that no additional
                disclosure is warranted, please explain why not.

    The following additional disclosure has been added to the discussion of stock market risk:

    As an example, the rapid and global spread of a highly contagious novel coronavirus respiratory disease, COVID-19, has resulted in
      extreme volatility in the financial markets and severe losses; reduced liquidity of many instruments; significant disruptions to business operations (including business closures); disruptions to supply chains, consumer demand and employee
      availability; and widespread uncertainty regarding the duration and long-term effects of this pandemic. Some sectors of the economy and individual issuers have experienced particularly large losses. In addition, the COVID-19 pandemic may result in a
      sustained economic downturn or a global recession. The ultimate economic fallout from the pandemic, and the long-term impact on economies, markets, industries and individual issuers, are not known. The COVID-19 pandemic could adversely affect the
      value and liquidity of a fund’s investments, impair a fund’s ability to satisfy redemption requests, and negatively impact fund performance. In addition, the outbreak of COVID-19, and measures taken to mitigate its effects, could result in
      disruptions to the services provided to the fund by its service providers.

              5.

              In the Portfolio Manager disclosure, please include the month and year that the Portfolio Manager joined
                the investment manager.

    We confirm that this update has been made.

              6.

              In the statement of additional information, in the section regarding concentration, please revise the
                language to read, “engaged in any particular industry or group of industries.”

    We confirm that this update has been made.

              7.

              We note that the registration statement includes language limiting the Funds to investing up to 25% of
                assets in a particular industry or group of industries. We also note disclosure regarding an internal trigger of 5% to 10% for those investment types that are considered non-principal investment strategies. However, in this section, it
                indicates that there are exceptions to this 5% to 10% trigger (including industry concentrations). Please explain further.

    Upon review, we have determined that as no exceptions exist and to avoid any confusion, it is appropriate to remove the following
      sentence. There are exceptions to the 5% to 10% of assets test, including, but not limited to, the percentage of a Fund’s assets invested in a single industry or in
          a single country.

              8.

              In the Director table, please add, “during the past five years” as noted in the instructions to Form
                N-1A.

    We confirm that this update has been made.

    We would be happy to provide you with any additional information you may require or with copies of any of the
      materials referred to above. Please direct any communications relating to this filing to:

    Ryan Charles

    Davis Selected Advisers, L.P.

    2949 E. Elvira Road, Suite 101

    Tucson, AZ 85756

    520-434-3778

    Sincerely,

    /s/ Ryan Charles

    Ryan Charles

    Vice President and General Counsel

        SELECTED FUNDS

        PROSPECTUS

        April 30, 2020

                Class S

                Class D

                Selected American Shares

                SLASX

                SLADX

                Selected International Fund

                SLSSX

                SLSDX

        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.

        Beginning on January 1, 2021, as permitted by regulations adopted by the SEC, paper copies of the Funds’ shareholder reports will
          no longer be sent by mail, unless you specifically request paper copies of the reports from your financial intermediary, such as a broker-dealer or bank. Instead, the reports will be made available on a website, and you will be notified by mail
          each time a report is posted and provided with a website link to access the report.

        If you already elected to receive shareholder reports electronically, you will not be affected by this change and you need not take
          any action. Please contact your financial intermediary to elect to receive shareholder reports and other Fund communications electronically.

        You may elect to receive all future reports in paper free of charge. Please contact your financial intermediary to inform them that
          you wish to continue receiving paper copies of Fund shareholder reports and for details regarding whether your election to receive reports in paper will apply to all funds held with your financial intermediary.

        Table of Contents

        Contents

                Selected American Shares Summary

                3

                Selected International Fund Summary

                7

                Additional Information About Investment Objectives, Principal Strategies and Principal Risks

                11

                Additional Information About Expenses, Fees and Performance

                14

                Non-Principal Investment Strategies and Risks

                14

                Management and Organization

                15

                Shareholder Information

                16

                How Your Shares Are Valued

                17

                Portfolio Holdings

                18

                How Selected Funds Pay Earnings

                18

                Federal Income Taxes

                19

                Fees and Expenses of the Funds

                19

                Fees Paid to Dealers and Other Financial Intermediaries

                20

                How to Choose a Share Class

                21

                How to Open an Account

                22

                Anti-Money Laundering Compliance

                22

                Retirement Plan Accounts

                22

                How to Buy, Sell and Exchange Shares

                22

                Buying More Shares

                23

                Selling Shares

                24

                Short-Term Trading Fee

                25

                Exchanging Shares

                27

                Frequent Purchases and Redemptions of Fund Shares

                27

                Telephone Transactions

                28

                Internet Transactions

                28

                Householding

                29

                Financial Highlights

                30

        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.

        Selected American
          Shares Summary

        Investment Objective

        The Fund seeks both capital growth and income. In the current market environment, income is expected to be low.

        Fees and Expenses of the Fund

        These tables describe the fees and expenses that you may pay if you buy and hold shares of the Fund.

                Shareholder Fees

                (fees paid directly from your investment)

                Class S shares

                Class D shares

                Maximum Sales Charge (Load) Imposed on Purchases

                (as a percentage of offering price)

                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)

                None

                None

                Maximum Sales Charge (Load) Imposed on Reinvested Dividends

                None

                None

                Annual Fund Operating Expenses

                (expenses that you pay each year as a percentage of the value of your investment)

                Class S shares

                Class D shares

                Management Fees

                0.55%

                0.55%

                Distribution and/or Service (12b-1) Fees

                0.25%

                0.00%

                Other Expenses

                0.18%

                0.11%

                Total Annual Operating Expenses

                0.98%

                0.66%

        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 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:

                1 Year

                3 Years

                5 Years

                10 Years

                Class S shares

                $100

                $312

                $542

                $1,201

                Class D shares

                $67

                $211

                $368

                $822

        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 11% 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 at least 80% of Selected American Shares’ net assets, plus any borrowing for investment purposes, in securities issued by American companies. The Fund invests principally in common stocks (including indirect holdings of
          common stock through depositary receipts) issued by large companies with market capitalizations of at least $10 billion. Historically, the Fund has invested a significant portion of its assets in financial services companies and in foreign
          companies, and may also invest in mid- and small-capitalization companies.

        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

          page 3

        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 Selected American Shar