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Correspondence 0001084060-23-000071 from SELECTED INTERNATIONAL FUND, INC (CIK 0000084237)

SELECTED INTERNATIONAL FUND, INC (CIK 0000084237)
Date: May 18, 2023 · CIK: 0000084237 · Accession: 0001084060-23-000071

AI Filing Summary & Sentiment

File numbers found in text: 811-00051, 811-01533

Date
May 18, 2023
Author
/s/ Lisa Cohen
Form
CORRESP
Company
SELECTED INTERNATIONAL FUND, INC (CIK 0000084237)

Letter

Securities and Exchange Commission Division of Investment Management Office of Disclosure and Review Attention: Lauren Hamilton Re: Selected American Shares, Inc. (40 Act File No.: 811-00051) Selected International Fund, Inc. (40 Act File No.: 811-01533)

Dear Ms. Hamilton:

This letter is in response to comments you provided on April 20, 2023, with respect to your review, pursuant to the Sarbanes-Oxley Act of 2002, of certain annual reports and other filings of the Registrants, as identified above. SEC comments are in bold, Registrants’ responses immediately follow.

1.

We noted disclosure of significant ownership in the funds per review of the financial statements. If you could, please explain how large shareholder or shareholder concentration risk is addressed in the summary and statutory prospectus. Please consider how such redemptions could result in tax consequences and negatively impact the funds’ NAV, liquidity, brokerage cost, and the ability to execute the funds’ investment strategy.

We find your requirement to include one additional risk, re-mail the summary prospectus, and sticker the statutory prospectus and statement of additional information beyond burdensome given that for each of the funds advised by Davis Selected Advisers, L.P. (including those not under examination), the following number of principal risks are already disclosed:

Affected Fund

# Principal Risks

Selected International Fund

Davis International Fund

Davis Appreciation & Income Fund

Davis Research Fund

Davis Select U.S. Equity ETF

Davis Select International ETF

Davis Select Financial ETF

Davis Select Worldwide ETF

Your requirement that one more risk be added immediately rather than waiting for its next renewal is unwarranted, unnecessary, and unduly burdensome. Affiliate ownership has been disclosed in the financial statement footnotes for a number of years, and given the cost to shareholders that would be associated with the immediate addition of the risk, we believe that it should be included at the next annual update of the respective filings.

Selected American Shares, Inc. and Selected International Fund, Inc. (collectively the “Registrants”) acknowledge that:

1.

The Registrants are responsible for the accuracy and adequacy of the disclosures in the Registrants’ filings;

2.

Staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filings; and

3.

The Registrants may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

In addition, we are aware that the Division of Enforcement has access to all information we provide to the staff of the Division of Investment Management in its review of Registrants’ filings or in response to staff comments on Registrants’ filings.

Please call the undersigned at (520) 434-3773 with any comments or questions.

Respectfully,
/s/ Lisa Cohen

Show Raw Text
CORRESP
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filename1.htm

    EDGAR CORRESPONDENCE

    May 18, 2023

    Securities and Exchange Commission

    Division of Investment Management

    Office of Disclosure and Review

    450 Fifth Street, N.W.

    Washington, D.C.  20549

    Attention: Lauren Hamilton

            Re:

            Selected American Shares, Inc. (40 Act File No.: 811-00051)

            Selected International Fund, Inc. (40 Act File No.: 811-01533)

    Dear Ms. Hamilton:

    This letter is in response to comments you provided on April 20, 2023, with respect to your review, pursuant to the Sarbanes-Oxley Act
      of 2002, of certain annual reports and other filings of the Registrants, as identified above. SEC comments are in bold, Registrants’ responses immediately follow.

              1.

              We noted disclosure of significant ownership in the funds per review of the financial
                statements. If you could, please explain how large shareholder or shareholder concentration risk is addressed in the summary and statutory prospectus. Please consider how such redemptions could result in tax consequences and negatively
                impact the funds’ NAV, liquidity, brokerage cost, and the ability to execute the funds’ investment strategy.

    We find your requirement to include one additional risk, re-mail the summary prospectus, and sticker the statutory prospectus and
      statement of additional information beyond burdensome given that for each of the funds advised by Davis Selected Advisers, L.P. (including those not under examination), the following number of principal risks are already disclosed:

            Affected Fund

            # Principal Risks

            Selected International Fund

            13

            Davis International Fund

            13

            Davis Appreciation & Income Fund

            18

            Davis Research Fund

            11

            Davis Select U.S. Equity ETF

            16

            Davis Select International ETF

            18

            Davis Select Financial ETF

            19

            Davis Select Worldwide ETF

            18

    Your requirement that one more risk be added immediately rather than waiting for its next renewal is unwarranted, unnecessary, and unduly burdensome. Affiliate ownership has been disclosed in the financial statement footnotes for a number of years, and given
      the cost to shareholders that would be associated with the immediate addition of the risk, we believe that it should be included at the next annual update of the respective filings.

    Selected American Shares, Inc. and Selected International Fund, Inc. (collectively the “Registrants”) acknowledge that:

              1.

              The Registrants are responsible for the accuracy and adequacy of the disclosures in the Registrants’ filings;

              2.

              Staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose
                the Commission from taking any action with respect to the filings; and

              3.

              The Registrants may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under
                the federal securities laws of the United States.

    In addition, we are aware that the Division of Enforcement has access to all information we provide to the staff of the Division of
      Investment Management in its review of Registrants’ filings or in response to staff comments on Registrants’ filings.

    Please call the undersigned at (520) 434-3773 with any comments or questions.

    Respectfully,

    /s/ Lisa Cohen

         Lisa Cohen

         Vice President and Secretary