SEC Company Response from FENIMORE ASSET MANAGEMENT TRUST (CIK 0000797136) — Apr 28, 2020
FENIMORE ASSET MANAGEMENT TRUST (CIK 0000797136)
Date: April 28, 2020 · CIK: 0000797136 · Accession: 0001398344-20-008550
AI Filing Summary & Sentiment
File numbers found in text: 811-4750
Letter
VIA EDGAR CORRESPONDENCE Division of Investment Management, 100 F Street, N. E. Washington, D.C. 20549 Re: Fenimore Asset Management Trust File Nos. 811-4750 and 33-7190
Dear Mr. Eskildsen:
On behalf of Fenimore Asset Management Trust (the “Trust”) and its three separate investment series, FAM Value Fund, FAM Dividend Focus Fund and FAM Small Cap Fund (the “Funds”), I wish to respond to the comment that you recently provided to me over the telephone with respect to your review, pursuant to Section 408 of the Sarbanes-Oxley Act of 2002, of the content of various of the Trust’s financial statement filings made on behalf of the Funds. The proposed response on behalf of the Trust to the comment that you provided is set forth below.
Comment: In the Trust’s Annual Report to Shareholders for the fiscal year ended December 31, 2019, Note No. 1 to the Financial Statements discloses that each of the Funds is a “diversified” open-end, management investment company registered under the Investment Company Act of 1940, as amended. In accordance with Item 16(a) of Form N-1A, similar disclosure should also be included in the Trust’s Statement of Additional Information noting that each of the Funds is classified as a “diversified” open-end, management investment company.
Response: The subject disclosure will be added to the Statement of Additional Information that is included in the Trust’s Registration Statement on Form N-1A at the time of the next annual update of the Registration Statement on April 29, 2020.
* * * *
Mr. Chad D. Eskildsen
Division of Investment Management
April 28, 2020
I trust that the foregoing is responsive to your comment.
Please do not hesitate to contact the undersigned by telephone at (202) 261-3364 or via e-mail at patrick.turley@dechert.com with any questions or comments you may have regarding the foregoing.
Very truly yours,
/s/ Patrick W.D. Turley
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DECHERT LLP
1900 K Street, N.W.
Washington, D.C. 20006
(202) 261-3300
April 28, 2020
VIA EDGAR CORRESPONDENCE
Mr. Chad D. Eskildsen
Staff Accountant
Division of Investment Management,
Disclosure Review and Accounting
U.S. Securities and Exchange Commission
100 F Street, N. E.
Washington, D.C. 20549
Re: Fenimore Asset Management Trust
File Nos. 811-4750 and 33-7190
Dear Mr. Eskildsen:
On behalf of Fenimore Asset
Management Trust (the “Trust”) and its three separate investment series, FAM Value Fund, FAM Dividend Focus Fund and
FAM Small Cap Fund (the “Funds”), I wish to respond to the comment that you recently provided to me over the telephone
with respect to your review, pursuant to Section 408 of the Sarbanes-Oxley Act of 2002, of the content of various of the Trust’s
financial statement filings made on behalf of the Funds. The proposed response on behalf of the Trust to the comment that you provided
is set forth below.
Comment: In the Trust’s
Annual Report to Shareholders for the fiscal year ended December 31, 2019, Note No. 1 to the Financial Statements discloses that
each of the Funds is a “diversified” open-end, management investment company registered under the Investment Company
Act of 1940, as amended. In accordance with Item 16(a) of Form N-1A, similar disclosure should also be included in the Trust’s
Statement of Additional Information noting that each of the Funds is classified as a “diversified” open-end, management
investment company.
Response: The subject
disclosure will be added to the Statement of Additional Information that is included in the Trust’s Registration Statement
on Form N-1A at the time of the next annual update of the Registration Statement on April 29, 2020.
* * * *
Mr. Chad D. Eskildsen
Division of Investment Management
April 28, 2020
I trust that the foregoing
is responsive to your comment.
Please do not hesitate
to contact the undersigned by telephone at (202) 261-3364 or via e-mail at patrick.turley@dechert.com with any questions
or comments you may have regarding the foregoing.
Very truly yours,
/s/ Patrick W.D. Turley
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