Correspondence 0001193125-25-072090 from MoA Funds Corp (CIK 0000795259)
MoA Funds Corp (CIK 0000795259)
Date: April 3, 2025 · CIK: 0000795259 · Accession: 0001193125-25-072090
AI Filing Summary & Sentiment
File numbers found in text: 811-05084
Letter
Division of Investment Management 100 F Street NE Washington DC 20549 Attn: Ms. Lisa Larkin Re: Comments on Post-Effective Amendment No. 70 under the Securities Act of 1933 and No. 71 under the Investment Company Act of 1940 (the “1940 Act”) to the Registration Statement on Form N-1A, filed with the Securities and Exchange Commission (the “Commission”) on February 13, 2025 (the “MoA Funds Registration Statement”) of MoA Funds Corporation (fka Mutual of America Investment Corporation) (File Nos. 033-06486 and 811-05084) (the “Registrant”)
Dear Ms. Larkin:
On behalf of the Registrant, set forth below are responses to follow up comments you provided by telephone on April 2, 2025, concerning the MoA Funds Registration Statement.
Set forth below are your comments with the Registrant’s response immediately following each comment. Per our telephone conversation, all changes mentioned herein will appear in the post-effective amendment to the registration statement that will be filed with the Commission under paragraph (b) of Rule 485 of the Securities Act of 1933 (the “Securities Act”) in April 2025.
Comment 9 (March 28, 2025)
SAI – Fundamental Investment Restrictions
The Commission Staff notes that the “Fundamental Investment Restrictions” section of the SAI states, “With respect to fundamental investment restriction #6 above: The MoA US Government Money Market Fund does not invest more than 25% of its total assets in the financial services industry. At the time of the next shareholder vote, the Fund will seek approval of the shareholders to remove from fundamental investment restriction #6 the language stating, ‘except that the MoA US Government Money market Fund may invest more than 25% of its total assets in the financial services industry.’”
Please advise whether there has been a shareholder vote or plans for a shareholder vote.
Mutual of America Life Insurance Company
320 Park Avenue, New York, NY 10022-6839
mutualofamerica.com
Response 9 (April 1, 2025)
The Registrant confirms that it has not yet held a shareholder vote on this matter and has no immediate plans to hold a shareholder vote. The Registrant notes that because the Fund now operates as a Government Money Market Fund it is not expected to concentrate in any industry and does not anticipate any benefit to submitting an amended policy on industry concentration to shareholders of the Fund if a meeting of shareholders of the Fund is held while the Fund continues to operate as a Government Money Market Fund.
Comment 1 (April 2, 2025)
The Staff continues to believe that regardless of whether the concentration policy is utilized, it impermissibly reserves discretion and should be remedied at the Registrant’s earliest convenience.
Response 1 (April 3, 2025)
The Registrant confirms that at the time of the next shareholder vote, the Fund will seek approval of the shareholders to remove from fundamental investment restriction #6 the language stating, “except that the MoA US Government Money market Fund may invest more than 25% of its total assets in the financial services industry.”
We believe that this submission responds fully to each of the aforementioned comments received from the Commission staff. If you have any questions regarding the Registrant’s responses, please do not hesitate to contact the undersigned at the above telephone number at your earliest convenience. We greatly appreciate your attention to this matter.
Sincerely,
/s/ Amy Latkin
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CORRESP 1 filename1.htm SEC Correspondence Amy Latkin Vice President and Senior Counsel w: 212.224.1840 amy.latkin@mutualofamerica.com April 3, 2025 U.S. Securities and Exchange Commission Division of Investment Management 100 F Street NE Washington DC 20549 Attn: Ms. Lisa Larkin Re: Comments on Post-Effective Amendment No. 70 under the Securities Act of 1933 and No. 71 under the Investment Company Act of 1940 (the “1940 Act”) to the Registration Statement on Form N-1A, filed with the Securities and Exchange Commission (the “Commission”) on February 13, 2025 (the “MoA Funds Registration Statement”) of MoA Funds Corporation (fka Mutual of America Investment Corporation) (File Nos. 033-06486 and 811-05084) (the “Registrant”) Dear Ms. Larkin: On behalf of the Registrant, set forth below are responses to follow up comments you provided by telephone on April 2, 2025, concerning the MoA Funds Registration Statement. Set forth below are your comments with the Registrant’s response immediately following each comment. Per our telephone conversation, all changes mentioned herein will appear in the post-effective amendment to the registration statement that will be filed with the Commission under paragraph (b) of Rule 485 of the Securities Act of 1933 (the “Securities Act”) in April 2025. Comment 9 (March 28, 2025) SAI – Fundamental Investment Restrictions The Commission Staff notes that the “Fundamental Investment Restrictions” section of the SAI states, “With respect to fundamental investment restriction #6 above: The MoA US Government Money Market Fund does not invest more than 25% of its total assets in the financial services industry. At the time of the next shareholder vote, the Fund will seek approval of the shareholders to remove from fundamental investment restriction #6 the language stating, ‘except that the MoA US Government Money market Fund may invest more than 25% of its total assets in the financial services industry.’” Please advise whether there has been a shareholder vote or plans for a shareholder vote. Mutual of America Life Insurance Company 320 Park Avenue, New York, NY 10022-6839 mutualofamerica.com Response 9 (April 1, 2025) The Registrant confirms that it has not yet held a shareholder vote on this matter and has no immediate plans to hold a shareholder vote. The Registrant notes that because the Fund now operates as a Government Money Market Fund it is not expected to concentrate in any industry and does not anticipate any benefit to submitting an amended policy on industry concentration to shareholders of the Fund if a meeting of shareholders of the Fund is held while the Fund continues to operate as a Government Money Market Fund. Comment 1 (April 2, 2025) The Staff continues to believe that regardless of whether the concentration policy is utilized, it impermissibly reserves discretion and should be remedied at the Registrant’s earliest convenience. Response 1 (April 3, 2025) The Registrant confirms that at the time of the next shareholder vote, the Fund will seek approval of the shareholders to remove from fundamental investment restriction #6 the language stating, “except that the MoA US Government Money market Fund may invest more than 25% of its total assets in the financial services industry.” We believe that this submission responds fully to each of the aforementioned comments received from the Commission staff. If you have any questions regarding the Registrant’s responses, please do not hesitate to contact the undersigned at the above telephone number at your earliest convenience. We greatly appreciate your attention to this matter. Sincerely, /s/ Amy Latkin Mutual of America Life Insurance Company 320 Park Avenue, New York, NY 10022-6839 mutualofamerica.com