Correspondence 0001213900-23-094913 from OBERWEIS FUNDS (CIK 0000803020)
OBERWEIS FUNDS (CIK 0000803020)
Date: Dec. 12, 2023 · CIK: 0000803020 · Accession: 0001213900-23-094913
AI Filing Summary & Sentiment
File numbers found in text: 811-04854
Letter
Chicago
New York
Washington, DC
London
San Francisco
Los Angeles
Singapore
Dallas
Miami
vedderprice.com
December 12, 2023 Renee M. Hardt
Shareholder
+1 312 609 7616
rhardt@vedderprice.com
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Deborah O’Neal
Re: The Oberweis Funds (the “Registrant”)
Post Effective Amendment No. 74 (Amendment No. 76) to
Registration Statement on Form N-1A
File Nos. 33-09093 and 811-04854
To the Commission:
On behalf of the Registrant, this letter is in response to the comments provided telephonically by the staff of the U.S. Securities and Exchange Commission (the “Commission”) to Vedder Price P.C. on November 20, 2023 with respect to Post Effective Amendment No. 74 (Amendment No. 76) to the Registrant’s Registration Statement on Form N-1A filed on October 6, 2023 (the “Registration Statement”) relating to the issuance of Institutional Class shares of the Oberweis International Opportunities Fund (the “Fund”), a series of the Registrant. Any capitalized terms used but not defined herein have the same meanings as given to them in the Registration Statement. Set forth below are the staff’s comments and the Registrant’s responses.
Prospectus – Footnote 3 to the Fee Table
Comment (1) Please clarify whether acquired fund fees and expenses are excluded from the expense limitation.
Response: The disclosure has been revised to state that acquired fund fees and expenses are excluded from the expense limitation.
Comment (2) The phrase which reads “however, the adviser is not obligated to reimburse the Fund for any amounts in excess of fees paid to the adviser” is not consistent with the description of the expense limitation agreement on page 17 of the SAI.
Response: The referenced disclosure has been deleted.
Comment (3) Please revise the last sentence to clarify that recoupment of reimbursed expenses may only occur three years from the date on which the reimbursement occurred.
Response: The disclosure has been revised accordingly.
222 North LaSalle Street | Chicago, Illinois 60601 | T +1 312 609 7500 | F +1 312 609 5005
Vedder Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, Vedder Price Pte. Ltd., which operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.
U.S. Securities and Exchange Commission
December 12, 2023
Page 2
Comment (4) Please confirm that the language in the last sentence “at the time of the recoupment” is correct; if not, please revise.
Response: The referenced language is correct; however, the next word should be “or” not “on” and should read “. . . if the recoupment does not cause the Fund’s expenses to exceed the expense limitation in place at the time of the recoupment or at the time of reimbursement, whichever is lower.”
* * *
Please call me at (312) 609-7616 if you have any questions.
Very
truly yours,
/s/
Renee M. Hardt
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Chicago
New York
Washington,
DC
London
San Francisco
Los Angeles
Singapore
Dallas
Miami
vedderprice.com
December 12, 2023
Renee M.
Hardt
Shareholder
+1 312 609 7616
rhardt@vedderprice.com
U.S. Securities and
Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Deborah O’Neal
Re: The Oberweis
Funds (the “Registrant”)
Post Effective Amendment No. 74 (Amendment No. 76) to
Registration Statement on Form N-1A
File Nos. 33-09093 and 811-04854
To the Commission:
On behalf of the
Registrant, this letter is in response to the comments provided telephonically by the staff of the U.S. Securities and Exchange Commission
(the “Commission”) to Vedder Price P.C. on November 20, 2023 with respect to Post Effective Amendment No. 74 (Amendment No.
76) to the Registrant’s Registration Statement on Form N-1A filed on October 6, 2023 (the “Registration Statement”)
relating to the issuance of Institutional Class shares of the Oberweis International Opportunities Fund (the “Fund”), a series
of the Registrant. Any capitalized terms used but not defined herein have the same meanings as given to them in the Registration Statement.
Set forth below are the staff’s comments and the Registrant’s responses.
Prospectus
– Footnote 3 to the Fee Table
Comment
(1) Please clarify whether acquired fund fees and expenses are excluded from the expense
limitation.
Response: The disclosure has been revised to state that acquired fund
fees and expenses are excluded from the expense limitation.
Comment (2) The
phrase which reads “however, the adviser is not obligated to reimburse the Fund for any amounts in excess of fees paid to the
adviser” is not consistent with the description of the expense limitation agreement on page 17 of the SAI.
Response: The referenced disclosure has been deleted.
Comment
(3) Please revise the last sentence to clarify that recoupment of reimbursed expenses may only occur
three years from the date on which the reimbursement occurred.
Response: The
disclosure has been revised accordingly.
222 North LaSalle Street | Chicago, Illinois 60601 | T +1 312
609 7500 | F +1 312 609 5005
Vedder
Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California,
Vedder Price Pte. Ltd., which operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.
U.S. Securities and
Exchange Commission
December 12, 2023
Page 2
Comment (4) Please
confirm that the language in the last sentence “at the time of the recoupment” is correct; if not, please
revise.
Response: The
referenced language is correct; however, the next word should be “or” not “on”
and should read “. . . if the recoupment does not cause the Fund’s
expenses to exceed the expense limitation in place at the time of the recoupment or at the
time of reimbursement, whichever is lower.”
* * *
Please call me at
(312) 609-7616 if you have any questions.
Very
truly yours,
/s/
Renee M. Hardt
Renee
M. Hardt
Shareholder
RMH/ser