Correspondence 0000051931-24-000527 from WASHINGTON MUTUAL INVESTORS FUND (CIK 0000104865)
WASHINGTON MUTUAL INVESTORS FUND (CIK 0000104865)
Date: May 15, 2024 · CIK: 0000104865 · Accession: 0000051931-24-000527
AI Filing Summary & Sentiment
File numbers found in text: 811-00604
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Investment Management, Disclosure Review and Accounting 100 F Street, NE Washington, D.C. 20549 Re: Washington Mutual Investors Fund (File Nos. 002-11051 and 811-00604) (the “Registrant”)
Dear Mr. Kernan:
This letter responds to a comment of the U.S. Securities and Exchange Commission (“SEC”) staff with respect to the staff’s review pursuant to the Sarbanes-Oxley Act of 2002 of certain filings of the Registrant for the fiscal year ended April 30, 2023. The SEC staff’s comment was provided by you to me and Phillip Garber of Dechert LLP in a telephonic discussion on April 9, 2024. The SEC staff’s comment and the response of the Registrant are set forth below:
Form N-CSR
1. Comment: With respect to the Registrant’s annual report covering the fiscal year ended April 30, 2023, the SEC staff notes that the transfer agency fees disclosed in the statement of operations may include amounts paid to third parties. To the extent that these fees include amounts accrued for payments made to financial intermediaries for sub-transfer agency or sub-recordkeeping services, please disclose these fees as a separate line item in the statement of operations if they exceed 5% of total expenses in accordance with Regulation S-X Rule 6-07(2)(b).
Response: The Registrant acknowledges the staff’s comment. The Registrant has a transfer agency arrangement with American Funds Service Company (“AFS”), a wholly owned subsidiary of the Registrant’s investment adviser, under which the Registrant compensates AFS for providing transfer agent services to each of the Registrant’s share classes. Any sub-transfer agency services provided by third party intermediaries are rendered under agreements with AFS (and not the Registrant); pursuant to these agreements, fees are paid by AFS to the third parties for performing transfer agent services on behalf of the Registrant’s shareholders.
In consideration of the arrangements described above, the transfer agent expenses shown in the Registrant’s statement of operations reflects the fees incurred between the Registrant and AFS. However, to provide added clarity to this arrangement, we plan to revise the transfer agent services disclosure in the notes to financial statements going forward, as follows:
Transfer agent services — The fund has a shareholder services agreement with AFS under which the fund compensates AFS for providing transfer agent services to each of the fund’s share classes. These services include recordkeeping, shareholder communications and transaction processing. In addition Under this agreement, the fund reimburses also pays sub-transfer agency fees to AFS. These fees are paid by AFS for amounts paid to third parties for performing transfer agent services on behalf of fund shareholders.
* * *
Should you have any questions or comments, please contact the undersigned at 949.442.6051.
Sincerely,
/s/ Kevin F. Cahill
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US Bank Tower
633 West 5th Street
Suite 4900
Los Angeles, CA 90071-2032
+1 213 808 5700 Main
+1 213 808 5760 Fax
www.dechert.com
Kevin F. Cahill
kevin.cahill@dechert.com
+1 949 442 6051 Direct
+1 949 681 8646 Fax
May 15, 2024
VIA EDGAR
John F. Kernan
Staff Accountant
United States Securities and Exchange Commission
Division of Investment Management, Disclosure Review
and Accounting
100 F Street, NE
Washington, D.C. 20549
Re: Washington Mutual Investors Fund (File Nos. 002-11051 and 811-00604) (the “Registrant”)
Dear Mr. Kernan:
This letter responds to a comment of the U.S. Securities
and Exchange Commission (“SEC”) staff with respect to the staff’s review pursuant to the Sarbanes-Oxley Act of 2002
of certain filings of the Registrant for the fiscal year ended April 30, 2023. The SEC staff’s comment was provided by you to me
and Phillip Garber of Dechert LLP in a telephonic discussion on April 9, 2024. The SEC staff’s comment and the response of the Registrant
are set forth below:
Form N-CSR
1. Comment: With respect to the Registrant’s annual report covering the fiscal year ended
April 30, 2023, the SEC staff notes that the transfer agency fees disclosed in the statement of operations may include amounts paid to
third parties. To the extent that these fees include amounts accrued for payments made to financial intermediaries for sub-transfer agency
or sub-recordkeeping services, please disclose these fees as a separate line item in the statement of operations if they exceed 5% of
total expenses in accordance with Regulation S-X Rule 6-07(2)(b).
Response: The Registrant
acknowledges the staff’s comment. The Registrant has a transfer agency arrangement with American Funds Service Company
(“AFS”), a wholly owned subsidiary of the Registrant’s investment adviser, under which the Registrant compensates
AFS for providing transfer agent services to each of the Registrant’s share classes. Any sub-transfer agency services provided
by third party intermediaries are rendered under agreements with AFS (and not the Registrant); pursuant to these agreements, fees
are paid by AFS to the third parties for performing transfer agent services on behalf of the Registrant’s shareholders.
In consideration of the arrangements described
above, the transfer agent expenses shown in the Registrant’s statement of operations reflects the fees incurred between the Registrant
and AFS. However, to provide added clarity to this arrangement, we plan to revise the transfer agent services disclosure in the notes
to financial statements going forward, as follows:
Transfer agent services
— The fund has a shareholder services agreement with AFS under which the fund compensates AFS for providing transfer agent services
to each of the fund’s share classes. These services include recordkeeping, shareholder communications and transaction processing.
In addition Under this agreement, the fund reimburses also pays sub-transfer agency fees to
AFS. These fees are paid by AFS for amounts paid to third parties for performing transfer agent services on
behalf of fund shareholders.
* * *
Should you have any questions or comments, please contact
the undersigned at 949.442.6051.
Sincerely,
/s/ Kevin F. Cahill
Kevin F. Cahill