Correspondence 0000035315-24-000766 from FIDELITY ADVISOR SERIES II (CIK 0000795422)
FIDELITY ADVISOR SERIES II (CIK 0000795422)
Date: Oct. 7, 2024 · CIK: 0000795422 · Accession: 0000035315-24-000766
AI Filing Summary & Sentiment
File numbers found in text: 811-04707
Letter
Converted by EDGARwiz
COMMENTS RECEIVED ON 10/02/2024
FROM DANIEL GREENSPAN
FIDELITY ADVISOR SERIES II (File Nos. 033-06516 and 811-04707)
Fidelity Advisor Limited Term Bond Fund
POST-EFFECTIVE AMENDMENT NO. 171
1)
“Fund Summary” (prospectus)
“Principal Investment Strategies”
C:
The Staff requests we revise to clarify if we intend to refer to net or total assets for purposes of the 80% test. If net, then, if a fund can borrow, the Staff notes it must include “plus any borrowings for investment purposes” when referring to net assets.
R:
The fund uses the definition of “assets” set forth in Rule 35d-1 for purposes of its 80% policy and we believe the current disclosure is appropriate and consistent with Rule 35d-1. Accordingly, we have not modified the disclosure.
2)
“Fund Summary” (prospectus)
“Principal Investment Risks”
C:
Because the fund’s strategies changed to investments in all types of debt, the Staff asserts there should be a separate risk associated with the risks of lower-quality debt investments, such as junk bonds.
R:
We believe the risks associated with investing in junk bonds are described in “Issuer-Specific Changes” and, therefore, the addition of a separate risk factor for this type of investment would be duplicative.
3)
“Fund Summary” (prospectus)
“Fee Table”
“You may qualify for sales charge discounts if you and your family invest, or agree to invest in the future, at least $ 50,000 in the fund or certain other Fidelity ® funds. More information about these and other discounts is available from your investment professional and in the "Fund Distribution" section beginning on page 33 of the prospectus. Different intermediaries may provide additional waivers or reductions of the sales charge. Please see "Sales Charge Waiver Policies Applied by Certain Intermediaries" in the "Appendix" section of the prospectus.”
C:
The Staff requests we remove the underlined portion for consistency with the form.
R:
We will modify the disclosure as follows:
“You may qualify for sales charge discounts if you and your family invest, or agree to invest in the future, at least $50,000 in the fund or certain other Fidelity® funds. More information about these and other discounts is available from your investment professional and in the "Fund Distribution" section beginning on page 33 of the prospectus and in the sales charge waiver appendix to the prospectus. Different intermediaries may provide additional waivers or reductions of the sales charge. Please see "Sales Charge Waiver Policies Applied by Certain Intermediaries" in the "Appendix" section of the prospectus.”
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CORRESP 1 filename1.htm Converted by EDGARwiz COMMENTS RECEIVED ON 10/02/2024 FROM DANIEL GREENSPAN FIDELITY ADVISOR SERIES II (File Nos. 033-06516 and 811-04707) Fidelity Advisor Limited Term Bond Fund POST-EFFECTIVE AMENDMENT NO. 171 1) “Fund Summary” (prospectus) “Principal Investment Strategies” C: The Staff requests we revise to clarify if we intend to refer to net or total assets for purposes of the 80% test. If net, then, if a fund can borrow, the Staff notes it must include “plus any borrowings for investment purposes” when referring to net assets. R: The fund uses the definition of “assets” set forth in Rule 35d-1 for purposes of its 80% policy and we believe the current disclosure is appropriate and consistent with Rule 35d-1. Accordingly, we have not modified the disclosure. 2) “Fund Summary” (prospectus) “Principal Investment Risks” C: Because the fund’s strategies changed to investments in all types of debt, the Staff asserts there should be a separate risk associated with the risks of lower-quality debt investments, such as junk bonds. R: We believe the risks associated with investing in junk bonds are described in “Issuer-Specific Changes” and, therefore, the addition of a separate risk factor for this type of investment would be duplicative. 3) “Fund Summary” (prospectus) “Fee Table” “You may qualify for sales charge discounts if you and your family invest, or agree to invest in the future, at least $ 50,000 in the fund or certain other Fidelity ® funds. More information about these and other discounts is available from your investment professional and in the "Fund Distribution" section beginning on page 33 of the prospectus. Different intermediaries may provide additional waivers or reductions of the sales charge. Please see "Sales Charge Waiver Policies Applied by Certain Intermediaries" in the "Appendix" section of the prospectus.” C: The Staff requests we remove the underlined portion for consistency with the form. R: We will modify the disclosure as follows: “You may qualify for sales charge discounts if you and your family invest, or agree to invest in the future, at least $50,000 in the fund or certain other Fidelity® funds. More information about these and other discounts is available from your investment professional and in the "Fund Distribution" section beginning on page 33 of the prospectus and in the sales charge waiver appendix to the prospectus. Different intermediaries may provide additional waivers or reductions of the sales charge. Please see "Sales Charge Waiver Policies Applied by Certain Intermediaries" in the "Appendix" section of the prospectus.”