SEC Company Response from AHA INVESTMENT FUNDS INC (CIK 0000831957) — Dec 16, 2004
AHA INVESTMENT FUNDS INC (CIK 0000831957)
Date: Dec. 16, 2004 · CIK: 0000831957 · Accession: 0000894189-04-002659
AI Filing Summary & Sentiment
Letter
VIA EDGAR Securities and Exchange Commission Division of Investment Management 450 Fifth Street, N.W. Washington, DC 20549 AHA Investment Funds, Inc.
Dear Ms. Browning:
This letter responds to the additional comments you gave to me on December 8, 2004 regarding the proposed post-effective amendment to the registration statement filed on behalf of AHA Investment Funds, Inc. on Form N-1A relating to Socially Responsible Equity Fund (the “Fund”). Each of your comments, as I understood them, is repeated below, with our responses immediately following. For convenience, I have attached clean and marked versions of the revised prospectus and SAI. The documents are marked against the versions filed pursuant to Rule 485(b) on December 3, 2004.
Prospectus
1. Investment Selection Process
Comment: Please include a complete list of the organizations that the Fund relies on to determine whether a company qualifies as socially responsible.
Response: Agreed. The following disclosure has been added: “To evaluate a company’s involvement in socially responsible activity, the Fund considers information provided by KLD Research & Analytics, Inc. or Investor Research Responsibility Center.” See page 3 of the enclosed prospectus.
2. Screened Activities
Comment: In the SAI, the Fund defines a company’s involvement in a screened activity as deriving more than 5% of its total revenue from tobacco, alcohol, gambling, abortion, or weaponry including non-consumer sales to the military, or that are involved in nuclear power. Please include the 5% threshold in the prospectus.
Ms. Kimberly Browning
December 9, 2004
Page 2
Response: Agreed. The requested disclosure has been added. See page 3 of the enclosed prospectus.
3. Weaponry Screen
Comment: The Fund includes weaponry as one of its screens. In addition, the prospectus states: “The Fund does not invest in any company whose core business is non-consumer sales to the military.” Please clarify that disclosure.
Response: The disclosure cited above was intended to emphasize the fact that the Fund does not invest in companies that derive revenue from the sale of weapons. To eliminate confusion with the Fund’s exclusionary screens, the disclosure has been deleted. The list of activities that the Fund screens has been revised to read as follows: “the Fund does not invest in a company that derives more than 5% of its total revenue from tobacco, alcohol, gambling, abortion or weaponry (whether to consumers or the military), or that is involved in nuclear power.” See page 3 of the enclosed prospectus.
4. Criteria for Socially Responsible Investing
Comment: The prospectus states: “There can be no assurance, however, that the Fund will screen all companies that derive revenue from those activities because certain information relating to the companies’ involvement in those activities may not be publicly available.” Please revise that language to explain the ramifications of the Fund investing in a company that does not meet its criteria for socially responsible investing.
Response: Agreed. The disclosure cited above has been deleted and replaced with the following: “Because information on a company’s involvement in those activities may not be publicly available, it is possible that the Fund’s holdings may include a company that does not meet its criteria for socially responsible investing. When the Fund discovers that a holding does not meet its criteria for socially responsible investing, the Fund will divest that holding as soon as reasonably practicable.” See page 3 of the enclosed prospectus.
5. Prior Performance of SKBA
Comment: Please verify that the investment objectives, policies, strategies and risks of the SRV composite are substantially similar to those of the Fund.
Response: Agreed. We have confirmed with the Fund’s investment adviser that the investment objectives, policies, strategies and risks of the SRV composite are substantially similar to those of the Fund. The investment policies of the SRV composite differ from those of the Fund in that they have not included a screen for abortion. The policies remain substantially similar, however, because since inception, the SRV composite has not invested in companies that the Fund’s abortion screen would exclude from the portfolio. We have added the following disclosure: “Had SKBA applied the exclusionary screen for abortion for the time periods below, the performance of the SRV composite would not have materially differed.” See page 20 of the enclosed prospectus.
Ms. Kimberly Browning
December 9, 2004
Page 3
* * * * *
On behalf of the Fund, I acknowledge that the Fund is responsible for the adequacy and accuracy of the disclosure in the filings; Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filing; and the Fund may not assert Staff comments as a defense in an proceeding initiated by the Commission or any person under the federal securities laws of the United States.
* * * * *
We believe that this information responds to all of your comments. Please call me to confirm the adequacy of our response at 312/807-4219.
Very truly yours,
/s/ Laura E. Simpson
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CORRESP 1 ahacorresp9th.htm AHA INVESTMENT FUNDS CORRESPONDENCE DECEMBER 9TH, 2004 Unassociated Document LAURA E. SIMPSON 312.807-4219 lsimpson@bellboyd.com DIRECT FAX: 312.345.9979 VIA EDGAR December 9, 2004 Ms. Kimberly Browning Securities and Exchange Commission Division of Investment Management 450 Fifth Street, N.W. Washington, DC 20549 AHA Investment Funds, Inc. Dear Ms. Browning: This letter responds to the additional comments you gave to me on December 8, 2004 regarding the proposed post-effective amendment to the registration statement filed on behalf of AHA Investment Funds, Inc. on Form N-1A relating to Socially Responsible Equity Fund (the “Fund”). Each of your comments, as I understood them, is repeated below, with our responses immediately following. For convenience, I have attached clean and marked versions of the revised prospectus and SAI. The documents are marked against the versions filed pursuant to Rule 485(b) on December 3, 2004. Prospectus 1. Investment Selection Process Comment: Please include a complete list of the organizations that the Fund relies on to determine whether a company qualifies as socially responsible. Response: Agreed. The following disclosure has been added: “To evaluate a company’s involvement in socially responsible activity, the Fund considers information provided by KLD Research & Analytics, Inc. or Investor Research Responsibility Center.” See page 3 of the enclosed prospectus. 2. Screened Activities Comment: In the SAI, the Fund defines a company’s involvement in a screened activity as deriving more than 5% of its total revenue from tobacco, alcohol, gambling, abortion, or weaponry including non-consumer sales to the military, or that are involved in nuclear power. Please include the 5% threshold in the prospectus. Ms. Kimberly Browning December 9, 2004 Page 2 Response: Agreed. The requested disclosure has been added. See page 3 of the enclosed prospectus. 3. Weaponry Screen Comment: The Fund includes weaponry as one of its screens. In addition, the prospectus states: “The Fund does not invest in any company whose core business is non-consumer sales to the military.” Please clarify that disclosure. Response: The disclosure cited above was intended to emphasize the fact that the Fund does not invest in companies that derive revenue from the sale of weapons. To eliminate confusion with the Fund’s exclusionary screens, the disclosure has been deleted. The list of activities that the Fund screens has been revised to read as follows: “the Fund does not invest in a company that derives more than 5% of its total revenue from tobacco, alcohol, gambling, abortion or weaponry (whether to consumers or the military), or that is involved in nuclear power.” See page 3 of the enclosed prospectus. 4. Criteria for Socially Responsible Investing Comment: The prospectus states: “There can be no assurance, however, that the Fund will screen all companies that derive revenue from those activities because certain information relating to the companies’ involvement in those activities may not be publicly available.” Please revise that language to explain the ramifications of the Fund investing in a company that does not meet its criteria for socially responsible investing. Response: Agreed. The disclosure cited above has been deleted and replaced with the following: “Because information on a company’s involvement in those activities may not be publicly available, it is possible that the Fund’s holdings may include a company that does not meet its criteria for socially responsible investing. When the Fund discovers that a holding does not meet its criteria for socially responsible investing, the Fund will divest that holding as soon as reasonably practicable.” See page 3 of the enclosed prospectus. 5. Prior Performance of SKBA Comment: Please verify that the investment objectives, policies, strategies and risks of the SRV composite are substantially similar to those of the Fund. Response: Agreed. We have confirmed with the Fund’s investment adviser that the investment objectives, policies, strategies and risks of the SRV composite are substantially similar to those of the Fund. The investment policies of the SRV composite differ from those of the Fund in that they have not included a screen for abortion. The policies remain substantially similar, however, because since inception, the SRV composite has not invested in companies that the Fund’s abortion screen would exclude from the portfolio. We have added the following disclosure: “Had SKBA applied the exclusionary screen for abortion for the time periods below, the performance of the SRV composite would not have materially differed.” See page 20 of the enclosed prospectus. Ms. Kimberly Browning December 9, 2004 Page 3 * * * * * On behalf of the Fund, I acknowledge that the Fund is responsible for the adequacy and accuracy of the disclosure in the filings; Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filing; and the Fund may not assert Staff comments as a defense in an proceeding initiated by the Commission or any person under the federal securities laws of the United States. * * * * * We believe that this information responds to all of your comments. Please call me to confirm the adequacy of our response at 312/807-4219. Very truly yours, /s/ Laura E. Simpson Laura E. Simpson Enclosures Copy to Savitri P. Pai, Esq.