Correspondence 0000313180-23-000002 from KEYCO BOND FUND INC (CIK 0000313180)
KEYCO BOND FUND INC (CIK 0000313180)
Date: Jan. 17, 2023 · CIK: 0000313180 · Accession: 0000313180-23-000002
AI Filing Summary & Sentiment
Reasoning
Letter
Re: Keyco Bond Fund, Inc. SOX Review of September 30, 2022 Financial Statements Filed on Form N-CSR and Other Company Filings
KEYCO BOND FUND, INC. 27777 Franklin Road - Suite 1575 Southfield, Michigan 48034 (248) 353-0790
Online Filing January 4, 2023
Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549
Attention: Christina Fettig, CPA Senior Staff Accountant
Ladies and Gentlemen:
On behalf of Keyco Bond Fund, Inc. (the Company), the information in this letter is being furnished in response to the verbal comments received by Ms. Carol Singer on behalf of the Company from the staff of the Securities and Exchange Commission via telephone on December 15, 2022.
1. Form N-CEN, Item C17.a.
Include the information for Comerica Bank, the processor of money market transactions, as an entity in Item C.17.a.
In future filings the Company will provide the information as requested.
2. Form N-CSR, industry/sector reporting
Include disclosure of the Company s holdings by sector.
Upon further review of this matter, management does not consider the Company to have any additional concentrations of credit risk in need of disclosure other than as reported in its financial and related reports.
Securities and Exchange Commission January 4, 2023 Page 2
3. Audited financial statements, footnote 5, Related Party Transactions
Keyco s Form N-CEN reports that Tauber Enterprises, LLC, a related party, serves as transfer agent for the Company. It is suggested that the transfer agent role be included as one of the services provided in footnote 5.
In future filings the Company will provide the information as requested.
4. Audited financial statements, footnote 2, Fair Value Measurements
Include specific language as to how the ETF and the money market fund are valued.
In future filings the Company will provide the information as requested.
5. Supplemental Information
Disclose risks specific to Michigan.
In future filings the Company will provide the information as requested.
6. Form N-CSR, Item 4, Principal Accountant Fees and Services
Attention is brought that subsections (i) and (j), both pertaining to auditors in foreign jurisdictions, are recent updates. Include responses addressing these subsections in the annual Form N-CSR even if the responses are not applicable.
In future filings the Company will provide the information as requested.
If you have any questions or comments concerning the response of the Company to the comments of the staff, please contact me at (248) 353-0790.
Securities and Exchange Commission January 4, 2023 Page 3
Very truly yours,
KEYCO BOND FUND, INC.
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<DOCUMENT> <TYPE>CORRESP <SEQUENCE>1 <FILENAME>filename1.txt <TEXT> KEYCO BOND FUND, INC. 27777 Franklin Road - Suite 1575 Southfield, Michigan 48034 (248) 353-0790 Online Filing January 4, 2023 Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549 Attention: Christina Fettig, CPA Senior Staff Accountant Ladies and Gentlemen: Re: Keyco Bond Fund, Inc. SOX Review of September 30, 2022 Financial Statements Filed on Form N-CSR and Other Company Filings On behalf of Keyco Bond Fund, Inc. (the Company), the information in this letter is being furnished in response to the verbal comments received by Ms. Carol Singer on behalf of the Company from the staff of the Securities and Exchange Commission via telephone on December 15, 2022. 1. Form N-CEN, Item C17.a. Include the information for Comerica Bank, the processor of money market transactions, as an entity in Item C.17.a. In future filings the Company will provide the information as requested. 2. Form N-CSR, industry/sector reporting Include disclosure of the Company s holdings by sector. Upon further review of this matter, management does not consider the Company to have any additional concentrations of credit risk in need of disclosure other than as reported in its financial and related reports. Securities and Exchange Commission January 4, 2023 Page 2 3. Audited financial statements, footnote 5, Related Party Transactions Keyco s Form N-CEN reports that Tauber Enterprises, LLC, a related party, serves as transfer agent for the Company. It is suggested that the transfer agent role be included as one of the services provided in footnote 5. In future filings the Company will provide the information as requested. 4. Audited financial statements, footnote 2, Fair Value Measurements Include specific language as to how the ETF and the money market fund are valued. In future filings the Company will provide the information as requested. 5. Supplemental Information Disclose risks specific to Michigan. In future filings the Company will provide the information as requested. 6. Form N-CSR, Item 4, Principal Accountant Fees and Services Attention is brought that subsections (i) and (j), both pertaining to auditors in foreign jurisdictions, are recent updates. Include responses addressing these subsections in the annual Form N-CSR even if the responses are not applicable. In future filings the Company will provide the information as requested. If you have any questions or comments concerning the response of the Company to the comments of the staff, please contact me at (248) 353-0790. Securities and Exchange Commission January 4, 2023 Page 3 Very truly yours, KEYCO BOND FUND, INC. /s/ Joel D. Tauber Joel D. Tauber President cc: Board of Directors of Keyco Bond Fund, Inc. Carol Singer for Keyco Bond Fund, Inc. </TEXT> </DOCUMENT>