SEC Company Response from NEW ECONOMY FUND (CIK 0000719608) — Jan 24, 2020
NEW ECONOMY FUND (CIK 0000719608)
Date: Jan. 24, 2020 · CIK: 0000719608 · Accession: 0000051931-20-000098
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File numbers found in text: 811-03735
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CORRESP
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filename1.htm
January 24, 2020
Mark Cowan
Senior Counsel
U.S. Securities and Exchange Commission
Division of Investment Management, Disclosure Review Office
100 F Street, N.E.
Washington, D.C. 20549
Re:
The New Economy Fund (the “Fund”)
File Nos. 002-83848 and 811-03735
Dear Mr. Cowan:
In response to the mark-up
you provided on December 18, 2019 to the Funds’ Post-Effective Amendment No. 70 under the Securities Act of 1933 (the “1933
Act”) and Amendment No. 66 under the Investment Company Act of 1940 (the “1940 Act”) to the Funds’
Registration Statement on Form N-1A, we hereby file Post-Effective Amendment No. 71 to the Registration Statement under the 1933
Act and Amendment No. 67 to the Registration Statement under the 1940 Act (such amendments, collectively, the “Amendment”)
pursuant to Rule 472 of the 1933 Act. We appreciate your prompt response to the previous filing.
We have summarized your
comments and provided our responses below. The Amendment reflects additional information that was not contained in the prior Registration
Statement.
Prospectus
Please include a completed fee table [without brackets] in correspondence
with the rest of your responses to comments at least five days prior to going effective.
Response: We have updated the
Registration Statement to address this comment. We have also copied the completed fee table below as requested.
Annual fund operating expenses (expenses that you pay each year as a percentage of the value of your investment)
Share class:
A
C
T
F-1
F-2
F-3
529-A
Management fees
0.38%
0.38%
0.38%
0.38%
0.38%
0.38%
0.38%
Distribution and/or service (12b-1) fees
0.25
1.00
0.25
0.25
none
none
0.22
Other expenses2
0.17
0.17
0.15
0.19
0.16
0.06
0.22
Total annual fund operating expenses
0.80
1.55
0.78
0.82
0.54
0.44
0.82
Share class:
529-C
529-E
529-T
529-F-1
R-1
R-2
R-2E
Management fees
0.38%
0.38%
0.38%
0.38%
0.38%
0.38%
0.38%
Distribution and/or service (12b-1) fees
1.00
0.50
0.25
0.00
1.00
0.75
0.60
Other expenses2
0.22
0.18
0.21
0.22
0.16
0.41
0.26
Total annual fund operating expenses
1.60
1.06
0.84
0.60
1.54
1.54
1.24
Share class:
R-3
R-4
R-5E
R-5
R-6
Management fees
0.38%
0.38%
0.38%
0.38%
0.38%
Distribution and/or service (12b-1) fees
0.50
0.25
none
none
none
Other expenses2
0.21
0.16
0.19
0.10
0.05
Total annual fund operating expenses
1.09
0.79
0.57
0.48
0.43
1 A contingent deferred sales
charge of 1.00% applies on certain redemptions made within 18 months following purchases
of $1 million or more made without an initial sales charge. Contingent deferred
sales charge is calculated based on the lesser of the offering price and market value
of shares being sold.
2 Restated to reflect current
fees.
The “Principal investment strategies”
state that the fund “may invest a significant portion of its assets in issuers based outside the United States, including
those based in developing countries.” Please clarify if the fund “may” or “intends to” invest in
these types of securities and define/specify what a “significant portion” means.
Response: The Fund is not required
to invest any specific portion of its assets in issuers based outside the United States, although it may invest up to 50% of its
assets in such issuers. To address this comment, we have amended the language in the prospectus to state that the fund “may
invest up to 50% of its assets in issuers based outside the United States, including those based in developing countries.”
In the risk factor on “Investing in growth-oriented
stocks”, consider eliminating the reference to “other equity securities” if not a principal investment. The only
equity investments referenced are common stocks in the principal strategy disclosure.
Response: While investing in
other equity-type securities (such as preferred stocks, convertible preferred stocks and convertible bonds) is not a principal
strategy of the Fund, our risk factor on “Investing in growth-oriented stocks” does refer to all types of equity securities.
Since investments in growth-oriented stocks may include all of these types of equity investments, we think it’s helpful to
note that to investors.
We note that the fund invests in convertible
securities. If the fund invests or expects to invest in contingent convertible securities (“CoCos”), the fund should
consider what, if any, disclosure is appropriate. The type and location of disclosure will depend on, among other things, the extent
to which the fund invests in CoCos, and the characteristics of the CoCos (e.g., the credit quality, the conversion triggers). If
CoCos are or will be a principal type of investment, the fund should provide a description of them and should provide appropriate
risk disclosure. In addition, please supplementally inform us whether the fund intends to invest or currently invests in CoCos
and the amount the fund currently invests in CoCos.
Response: We inform you supplementally
that the Fund does not currently invest, or intend to invest significantly, in CoCos. Accordingly, there is no need to add disclosure
on investment in CoCos to the prospectus at this time. However, since it is possible that the Fund could invest in CoCos in the
future, we included disclosure on investment in CoCos in the statement of additional information.
Please disclose Brexit risks, if applicable.
Response: The Fund is actively
managed and relies on the professional judgement of its investment adviser to make decisions about the Fund’s portfolio investments.
It is not an investment strategy of the Fund to invest in securities of issuers in the United Kingdom. Accordingly, we respectfully
decline to disclose Brexit risks at this time. However, we note supplementally that, because the investment portfolio of the Fund
is actively managed, and because, from time to time, the Fund may have significant exposure to a particular country, region, industry
or sector, the Fund’s prospectus includes disclosure regarding the risk of such exposure.
Please disclose any investment strategy
that gives rise to the principal risks associated with investments in small companies (including what is considered a 'small' company).
Response: We have added the
following sentence to the strategy disclosure to address this comment:
“The fund may also invest in the
stocks of smaller capitalization companies (typically companies with market capitalizations of $6.0 billion and below at the time
of purchase).”
The parenthetical providing detail
on what is considered a “small” company has only been added to the statutory prospectus in accordance with the SEC’s
guidance that the Item 4 disclosure should summarize the more fulsome disclosure in Item 9.
If the fund currently has, or expects to have,
as a result of the change in investment objectives, any significant exposure to a particular country, region, industry or sector,
please disclose in the principal strategy section.
Response: The Fund is actively
managed and relies on the professional judgment of its investment adviser to make decisions about the Fund’s portfolio investments.
It is not an investment strategy of the Fund to invest in securities of issuers in any particular country, region, industry or
sector in any amount. However, because the investment portfolio of the Fund is actively managed and because, from time to time,
the Fund may have significant exposure to a particular country, region, industry or sector, the Fund’s prospectus includes
disclosure regarding the risk of such exposure.
The disclosure states that the Fund’s
daily cash balance may be invested in one or more money market or similar funds managed by the investment adviser or its affiliates.
Please confirm supplementally that, in accordance with Item 3, Instr. 3(f), if "acquired fund fees and expenses" (AFFE)
exceed 0.01% of the average net assets of the Fund, the Fund will include a line item in the Fee Table for AFFE.
Response: We confirm supplementally
that, in accordance with Item 3, Instruction 3(f), if “acquired fund fees and expenses” (AFFE) exceed 0.01% of the
average net assets of the Fund, the Fund will include a line item in the Fee Table for AFFE.
Please explain to the staff whether the
fund will include 11/20/19 FYE results. If not, please include semi-annual results (May 31, 2019).
Response: We confirm that the
Fund will include 11/30/19 FYE results in the final filing.
Thank you for your consideration
of our responses to your comments. If you have any questions, please do not hesitate to contact me at (213) 615-0423.
Sincerely,
Rachel V. Nass
Counsel