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: 0000894189-04-002660
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 10, 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.
Prospectus
1. Investment Selection Process
Comment: Please confirm that the Fund does not have a contractual relationship with KLD or IRRC. If the Fund has a contractual relationship with KLD or IRRC, please disclose that fact, as well as the amount of the fee paid by the Fund, and file the contracts as exhibits to the registration statement.
Response: We have confirmed with the Fund’s investment adviser that the Fund does not have a contractual relationship with KLD or IRRC. The Fund does not pay KLD or IRRC any fees.
2. Screened Activities
Comment: On page 3, the prospectus states: “As a general matter, 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.” Please delete “as a general matter” from that sentence.
Ms. Kimberly Browing
December 10, 2004
Page 2
Response: Agreed. The requested change has been made. See page 3 of the enclosed prospectus.
3. Criteria for Socially Responsible Investing
Comment: After listing the screens used in the investment selection process, the prospectus states: “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.” Please indicate that the Fund considers publicly available information in evaluating a company’s involvement in socially responsible activity.
Response: Agreed. We have revised the disclosure to indicate that the Fund considers publicly available information in evaluating a company’s involvement in socially responsible activity. To make the language as clear as possible, we added this disclosure to the first sentence of the paragraph to indicate the sources of the information used to evaluate a company’s involvement in socially responsible activity. The disclosure reads as follows: “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, as well as publicly available information.” See page 3 of the enclosed prospectus.
* * * * *
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 ahacorresp10th.htm AHA INVESTMENT FUNDS CORRESPONDENCE DECEMBER 10TH, 2004 Unassociated Document LAURA E. SIMPSON 312.807-4219 lsimpson@bellboyd.com DIRECT FAX: 312.345.9979 VIA EDGAR December 10, 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 10, 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. Prospectus 1. Investment Selection Process Comment: Please confirm that the Fund does not have a contractual relationship with KLD or IRRC. If the Fund has a contractual relationship with KLD or IRRC, please disclose that fact, as well as the amount of the fee paid by the Fund, and file the contracts as exhibits to the registration statement. Response: We have confirmed with the Fund’s investment adviser that the Fund does not have a contractual relationship with KLD or IRRC. The Fund does not pay KLD or IRRC any fees. 2. Screened Activities Comment: On page 3, the prospectus states: “As a general matter, 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.” Please delete “as a general matter” from that sentence. Ms. Kimberly Browing December 10, 2004 Page 2 Response: Agreed. The requested change has been made. See page 3 of the enclosed prospectus. 3. Criteria for Socially Responsible Investing Comment: After listing the screens used in the investment selection process, the prospectus states: “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.” Please indicate that the Fund considers publicly available information in evaluating a company’s involvement in socially responsible activity. Response: Agreed. We have revised the disclosure to indicate that the Fund considers publicly available information in evaluating a company’s involvement in socially responsible activity. To make the language as clear as possible, we added this disclosure to the first sentence of the paragraph to indicate the sources of the information used to evaluate a company’s involvement in socially responsible activity. The disclosure reads as follows: “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, as well as publicly available information.” See page 3 of the enclosed prospectus. * * * * * 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.