Correspondence 0001213900-25-060499 from OBERWEIS FUNDS (CIK 0000803020)
OBERWEIS FUNDS (CIK 0000803020)
Date: July 1, 2025 · CIK: 0000803020 · Accession: 0001213900-25-060499
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 811-4854
Letter
July 2, 2025 Renee M. Hardt Shareholder +1 (312) 609 7616 rhardt@vedderprice.com VIA EDGAR Mr. Jeffrey W. Long Division of Investment Management Securities and Exchange Commission 100 F Street NE Washington, D.C. 20549
Re: The Oberweis Funds (File No. 811-4854)
Dear Mr. Long:
On behalf of The Oberweis Funds (the "Registrant"), this letter is in response to our telephone conversation on June 26, 2025 regarding the Registrant's Form N-CSR for the period ended December 31, 2024.
1. Comment : Certain Funds of the Registrant have expense limitation arrangements in place pursuant to which the Adviser may recoup expenses previously reimbursed. Please disclose in the notes to the financial statements the potential recoupments by year.
Response: The disclosure will be included in future reports on Form N-CSR.
2. Comment : The Institutional Class shares of the Funds have a minimum investment requirement that is greater than $10,000. In the Performance of Hypothetical Investment section in the tailored shareholder reports, the Institutional Class should calculate the hypothetical investment performance based on the required minimum initial investment as required by Form N-1A, Item 27A(d)(2)(i), Instruction 1(d).
Response: The Registrant will include this disclosure in future tailored shareholder reports.
3. Comment : The Registrant's Form N-CSR did not include Item 4(i) and (j). Please include these sub-items even if the response is Not Applicable.
Response: The Registrant will include these items in future reports on Form N-CSR.
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.
Mr. Jeffrey W. Long
July 2, 2025
Page 2
4. Comment : The certifications in Form N-CSR, Item 19(a)(3) require the certifying officers in paragraph 4(d) to certify that they have disclosed any change in the Registrant's internal control over financial reporting that occurred during the period covered by the report that has materially affected, or is reasonably likely to material affect the Registrant's internal control over financial reporting. In addition, the certifying officers should certify as Principal Executive Officer and Principal Financial Officer, respectively, rather than as President and Treasurer.
Response: The certifications will be revised accordingly in future reports on Form N-CSR.
* * *
Please call me at (312) 609-7616 if you have any questions.
Very truly yours,
/s/ Renee M. Hardt
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CORRESP 1 filename1.htm Chicago New York Washington, DC London San Francisco Los Angeles Singapore Dallas Miami vedderprice.com July 2, 2025 Renee M. Hardt Shareholder +1 (312) 609 7616 rhardt@vedderprice.com VIA EDGAR Mr. Jeffrey W. Long Division of Investment Management Securities and Exchange Commission 100 F Street NE Washington, D.C. 20549 Re: The Oberweis Funds (File No. 811-4854) Dear Mr. Long: On behalf of The Oberweis Funds (the "Registrant"), this letter is in response to our telephone conversation on June 26, 2025 regarding the Registrant's Form N-CSR for the period ended December 31, 2024. 1. Comment : Certain Funds of the Registrant have expense limitation arrangements in place pursuant to which the Adviser may recoup expenses previously reimbursed. Please disclose in the notes to the financial statements the potential recoupments by year. Response: The disclosure will be included in future reports on Form N-CSR. 2. Comment : The Institutional Class shares of the Funds have a minimum investment requirement that is greater than $10,000. In the Performance of Hypothetical Investment section in the tailored shareholder reports, the Institutional Class should calculate the hypothetical investment performance based on the required minimum initial investment as required by Form N-1A, Item 27A(d)(2)(i), Instruction 1(d). Response: The Registrant will include this disclosure in future tailored shareholder reports. 3. Comment : The Registrant's Form N-CSR did not include Item 4(i) and (j). Please include these sub-items even if the response is Not Applicable. Response: The Registrant will include these items in future reports on Form N-CSR. 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. Mr. Jeffrey W. Long July 2, 2025 Page 2 4. Comment : The certifications in Form N-CSR, Item 19(a)(3) require the certifying officers in paragraph 4(d) to certify that they have disclosed any change in the Registrant's internal control over financial reporting that occurred during the period covered by the report that has materially affected, or is reasonably likely to material affect the Registrant's internal control over financial reporting. In addition, the certifying officers should certify as Principal Executive Officer and Principal Financial Officer, respectively, rather than as President and Treasurer. Response: The certifications will be revised accordingly in future reports on Form N-CSR. * * * 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 cc: Eric V. Hannemann