SEC Company Response from VALUE LINE US GOVERNMENT SECURITIES FUND INC (CIK 0000352430) — Dec 22, 2004
VALUE LINE US GOVERNMENT SECURITIES FUND INC (CIK 0000352430)
Date: Dec. 22, 2004 · CIK: 0000352430 · Accession: 0000950136-04-004480
AI Filing Summary & Sentiment
File numbers found in text: 811-03171
Letter
BY EDGAR December 22, 2004 Mr. Dominic Minore Division of Investment Management United States Securities and Exchange Commission 450 Fifth Street NW Washington, DC 20549
Re: Value Line U.S. Government Securities Fund, Inc. File Nos. 2-71928; 811-03171
Dear Mr. Minore:
This letter is in response to the comments that you communicated to me by telephone on December 13, 2004 regarding the above-named Fund.
1. Disclosure of risks in investing in securities issued by Freddie Mac and Fannie Mae. We believe that the disclosure on pages 2 and 8 of the Prospectus are adequate but we have made some minor additions.
2. Disclosure required by the new instruction to Item 6(a)(1). We are adding additional material under the caption "Net Asset Value" as follows: "The use of fair value pricing by the Fund may cause the NAV to differ from the NAV that would be calculated using closing market prices."
3. Under the caption "Frequent Purchases and Redemption of Fund Shares" we are eliminating references to market timing and are adding the following: "The Adviser applies uniformly these restrictions in all cases" at the end of the third paragraph. We are also revising the second bullet to read: "makes more than four exchanges out of the Fund during a calendar year." We are also moving the section so that it will appear following "By Exchange" on page 14.
4. To comply more closely with Items 11(f)(vi) and (vii), we are adding under "Disclosure of Portfolio Holdings" in the Statement of Additional Information the names of other rating agencies to which portfolio holdings information may be distributed. We are also revising the penultimate sentence in the third paragraph to read as follows: "Except as stated above, unless there are legitimate business purposes for selective disclosure and other conditions designed to protect the Fund and its shareholders are met, the Fund does not provide or permit others to disclose the Fund's portfolio holdings to any person." At the end of the last paragraph of this section, the following is being added: "and may require the Adviser to provide reports on its implementation from time to time or require that the Fund's Chief Compliance Officer monitor compliance with this policy.
In connection with this response, the Fund acknowledges that
A. The Fund is responsible for the adequacy and accuracy of the disclosure in the filings;
B. 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 filing; and
C. The Fund 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.
Very truly yours,
Peter D. Lowenstein
Legal Counsel
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CORRESP
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file001.htm
CORRESPONDENCE
BY EDGAR
December 22, 2004
Mr. Dominic Minore
Division of Investment Management
United States Securities and Exchange Commission
450 Fifth Street NW
Washington, DC 20549
Re: Value Line U.S. Government Securities Fund, Inc.
File Nos. 2-71928; 811-03171
Dear Mr. Minore:
This letter is in response to the comments that you communicated to me by
telephone on December 13, 2004 regarding the above-named Fund.
1. Disclosure of risks in investing in securities issued by Freddie
Mac and Fannie Mae. We believe that the disclosure on pages 2 and
8 of the Prospectus are adequate but we have made some minor
additions.
2. Disclosure required by the new instruction to Item 6(a)(1). We
are adding additional material under the caption "Net Asset
Value" as follows: "The use of fair value pricing by the Fund may
cause the NAV to differ from the NAV that would be calculated
using closing market prices."
3. Under the caption "Frequent Purchases and Redemption of Fund
Shares" we are eliminating references to market timing and are
adding the following: "The Adviser applies uniformly these
restrictions in all cases" at the end of the third paragraph. We
are also revising the second bullet to read: "makes more than
four exchanges out of the Fund during a calendar year." We are
also moving the section so that it will appear following "By
Exchange" on page 14.
4. To comply more closely with Items 11(f)(vi) and (vii), we are
adding under "Disclosure of Portfolio Holdings" in the Statement
of Additional Information the names of other rating agencies to
which portfolio holdings information may be distributed. We are
also revising the penultimate sentence in the third paragraph to
read as follows: "Except as stated above, unless there are
legitimate business purposes for selective disclosure and other
conditions designed to protect the Fund and its shareholders are
met, the Fund does not provide or permit others to disclose the
Fund's portfolio holdings to any person." At the end of the last
paragraph of this section, the following is being added: "and may
require the Adviser to provide reports on its implementation from
time to time or require that the Fund's Chief Compliance Officer
monitor compliance with this policy.
In connection with this response, the Fund acknowledges that
A. The Fund is responsible for the adequacy and accuracy of the
disclosure in the filings;
B. 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 filing;
and
C. The Fund 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.
Very truly yours,
Peter D. Lowenstein
Legal Counsel
PDL:psp
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