SEC Company Response from FIRST AMERICAN FUNDS INC (CIK 0000356134) — Oct 21, 2004
FIRST AMERICAN FUNDS INC (CIK 0000356134)
Date: Oct. 21, 2004 · CIK: 0000356134 · Accession: 0000897101-04-002199
AI Filing Summary & Sentiment
File numbers found in text: 811-03313
Letter
KATHLEEN L. PRUDHOMME (612) 343-7973 FAX (612) 340-8738 PRUDHOMME.KATHLEEN@DORSEY.COM October 21, 2004 Ms. Kimberly Browning Office of Disclosure and Review Division of Investment Management Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549
Re: First American Funds, Inc. Post-Effective Amendment Number 50 to Registration Statement SEC File Nos. 2-74747 and 811-03313
Dear Ms. Browning:
On October 15, 2004, First American Funds, Inc. (the "Fund") filed post-effective amendment number 50 to its registration statement for the purpose of adding the U.S. Treasury Money Market Fund as a series of the Fund. Accompanying that filing was an acceleration request from the Fund and Quasar Distributors, LLC, the principal distributor of the Fund's shares, requesting acceleration of such filing to October 25, 2004 or as soon thereafter as possible. In connection with such acceleration request, we hereby acknowledge the following on behalf of the Fund:
1. Should the Securities and Exchange Commission (the "Commission") or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing.
2. The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Fund from its full responsibility for the adequacy and accuracy of the disclosure in the filing.
<PAGE> [LOGO] DORSEY
October 21, 2004 Page 2
3. The Fund may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
This letter also serves to confirm that U.S. Bancorp Asset Management, Inc., the investment adviser to the U.S. Treasury Money Market Fund, will not have the right to be reimbursed for any fee waivers and expense reimbursements made pursuant to the contractual expense limitations disclosed in the above-referenced Registration Statement.
Please feel free to call me if you have any additional questions or comments.
Very truly yours,
/s/ Kathleen L. Prudhomme
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<DOCUMENT>
<TYPE>CORRESP
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<TEXT>
[LOGO] DORSEY & WHITNEY LLP
KATHLEEN L. PRUDHOMME
(612) 343-7973
FAX (612) 340-8738
PRUDHOMME.KATHLEEN@DORSEY.COM
October 21, 2004
Ms. Kimberly Browning
Office of Disclosure and Review
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: First American Funds, Inc.
Post-Effective Amendment Number 50 to Registration Statement
SEC File Nos. 2-74747 and 811-03313
Dear Ms. Browning:
On October 15, 2004, First American Funds, Inc. (the "Fund") filed
post-effective amendment number 50 to its registration statement for the purpose
of adding the U.S. Treasury Money Market Fund as a series of the Fund.
Accompanying that filing was an acceleration request from the Fund and Quasar
Distributors, LLC, the principal distributor of the Fund's shares, requesting
acceleration of such filing to October 25, 2004 or as soon thereafter as
possible. In connection with such acceleration request, we hereby acknowledge
the following on behalf of the Fund:
1. Should the Securities and Exchange Commission (the "Commission") or
the staff, acting pursuant to delegated authority, declare the filing
effective, it does not foreclose the Commission from taking any action
with respect to the filing.
2. The action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Fund from its full responsibility for the adequacy and
accuracy of the disclosure in the filing.
<PAGE>
[LOGO] DORSEY
October 21, 2004
Page 2
3. The Fund may not assert this action as a defense in any proceeding
initiated by the Commission or any person under the federal securities
laws of the United States.
This letter also serves to confirm that U.S. Bancorp Asset Management, Inc., the
investment adviser to the U.S. Treasury Money Market Fund, will not have the
right to be reimbursed for any fee waivers and expense reimbursements made
pursuant to the contractual expense limitations disclosed in the
above-referenced Registration Statement.
Please feel free to call me if you have any additional questions or comments.
Very truly yours,
/s/ Kathleen L. Prudhomme
Kathleen L. Prudhomme
</TEXT>
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