Correspondence 0001133228-25-001290 from GLENMEDE FUND INC (CIK 0000835663)
GLENMEDE FUND INC (CIK 0000835663)
Date: Feb. 21, 2025 · CIK: 0000835663 · Accession: 0001133228-25-001290
AI Filing Summary & Sentiment
File numbers found in text: 811-05577
Letter
VIA EDGAR CORRESPONDENCE Division of Investment Management 100 F Street N.E. Washington, D.C. 20549 Re: The Glenmede Fund, Inc. - Registration Nos. 33-22884 and 811-05577 (the “Fund” or “Registrant”)
Dear Ms. Im-Tang:
We filed a response letter earlier today to respond to your comments provided on February 13, 2025, regarding the Fund’s Post-Effective Amendment (“PEA”) No. 120 on Form N-1A. PEA No. 120 was filed with Securities Exchange Commission (“SEC”) pursuant to Rule 485(a) under the Securities Act of 1933, as amended, on December 30, 2024 (the “Response Letter”).
Attached to this letter as Exhibit A are the completed fee table and expense examples for all Portfolios as requested by Comment 1 of the Response Letter.
Please contact me at (617) 662-3969 if you have any questions regarding the Registrant’s responses.
Very truly yours,
/s/ Francine S. Hayes
Show Raw Text
CORRESP
1
filename1.htm
The Glenmede Fund, Inc.
c/o State Street Bank and Trust Company
One Congress Street, Suite 1
Boston, MA 02114
February 21, 2025
VIA EDGAR CORRESPONDENCE
U.S. Securities and Exchange Commission
Attn: Ms. Soo Im-Tang, Esq.
Division of Investment Management
Disclosure Review Office
100 F Street N.E.
Washington, D.C. 20549
Re:
The Glenmede Fund, Inc. - Registration Nos. 33-22884 and 811-05577
(the “Fund” or “Registrant”)
Dear Ms. Im-Tang:
We filed a response letter earlier today to respond
to your comments provided on February 13, 2025, regarding the Fund’s Post-Effective Amendment (“PEA”) No.
120 on Form N-1A. PEA No. 120 was filed with Securities Exchange Commission (“SEC”) pursuant to Rule 485(a) under the Securities
Act of 1933, as amended, on December 30, 2024 (the “Response Letter”).
Attached to this letter as Exhibit A are the completed
fee table and expense examples for all Portfolios as requested by Comment 1 of the Response Letter.
Please contact me at (617) 662-3969 if you have any questions regarding
the Registrant’s responses.
Very truly yours,
/s/ Francine S. Hayes
Francine S. Hayes
Exhibit A - Fees and Expenses
of the Portfolios
Disciplined U.S. Equity Portfolio (formerly, Quantitative U.S. Large
Cap Core Equity Portfolio)
(Institutional Shares)
Fees and Expenses of the Portfolio
This table describes the fees and expenses that you may pay if
you buy, hold, and sell shares of the Portfolio. You may pay brokerage commissions and other fees to financial intermediaries which
are not reflected in the table and example below.
Institutional
Shares
Annual Portfolio Operating Expenses
(expenses that you
pay each year as a percentage of the value of your investment)
Management Fees
0.55%
Other Expenses
0.11%
Total Annual Portfolio Operating Expenses
0.66%
Example
This Example is intended to help you compare the cost of investing in the
Portfolio’s Institutional Shares with the cost of investing in other mutual funds. The Example assumes that you invest $10,000
in the Portfolio for the time periods indicated and then hold or redeem all of your shares at the end of those periods. The Example also
assumes that your investment has a 5% return each year and that the Portfolio’s operating expenses remain the same. Although your
actual costs may be higher or lower, based on these assumptions your costs would be:
1
Year
3
Years
5
Years
10
Years
$67
$211
$368
$822
Disciplined U.S. Growth Equity Portfolio (formerly, Quantitative
U.S. Large Cap Growth Equity Portfolio)
(Institutional Shares)
Fees and Expenses of the Portfolio
This table describes the fees and expenses that you may pay if
you buy, hold, and sell shares of the Portfolio. You may pay brokerage commissions and other fees to financial intermediaries which
are not reflected in the table and example below.
Institutional
Shares
Annual Portfolio Operating Expenses
(expenses that you
pay each year as a percentage of the value of your investment)
Management Fees
0.55%
Other Expenses
0.11%
Total Annual Portfolio Operating Expenses
0.66%
Example
This Example is intended to help you compare the cost of investing in the
Portfolio’s Institutional Shares with the cost of investing in other mutual funds. The Example assumes that you invest $10,000
in the Portfolio for the time periods indicated and then hold or redeem all of your shares at the end of those periods. The Example also
assumes that your investment has a 5% return each year and that the Portfolio’s operating expenses remain the same. Although your
actual costs may be higher or lower, based on these assumptions your costs would be:
1
Year
3
Years
5
Years
10
Years
$67
$211
$368
$822
Long/Short Equity Portfolio (formerly, Quantitative U.S. Long/Short
Equity Portfolio)
(Institutional Shares)
Fees and Expenses of the Portfolio
This table describes the fees and expenses that you may pay if
you buy, hold, and sell shares of the Portfolio. You may pay brokerage commissions and other fees to financial intermediaries which
are not reflected in the table and example below.
Institutional
Shares
Annual Portfolio Operating Expenses
(expenses that you
pay each year as a percentage of the value of your investment)
Management Fees
1.20%
Other Expenses
0.32%
Short Sale Expenses
1.27%
Total Other Expenses
1.59%
Total Annual Portfolio Operating Expenses
2.79%
Fee Waivers and Expense Reimbursements1
0.47%
Net Expenses
2.32%
1 Glenmede
Investment Management LP (the “Advisor”) has contractually agreed to waive a
portion of its Management Fee so that the Management Fee is 0.85% of the Portfolio’s
average daily net assets and to waive an additional portion of its Management Fee and/or
reimburse the Portfolio to the extent that total annual operating expenses of the Portfolio’s
Institutional Shares exceed 1.05% of the average daily net assets of the Portfolio’s
Institutional Shares (excluding Acquired Fund fees and expenses, short sale dividends, prime
broker interest, brokerage commissions, taxes, interest, and extraordinary expenses). The
Advisor has contractually agreed to these waivers and/or reimbursements until at least February
28, 2026 and may discontinue this arrangement at any time thereafter. This contractual fee
waiver agreement may not be terminated before February 28, 2026 without the approval of The
Glenmede Fund, Inc.’s (the “Fund”) Board of Directors (the “Board”).
Example
This Example is intended to help you compare the cost of investing
in the Portfolio’s Institutional Shares with the cost of investing in other mutual funds. The Example assumes that you invest $10,000
in the Portfolio for the time periods indicated and then hold or redeem all of your shares at the end of those periods. The Example also
assumes that your investment has a 5% return each year and that the Portfolio’s operating expenses remain the same, taking into
account the fee waiver in the first year of each period. Although your actual costs may be higher or lower, based on these assumptions
your costs would be:
1
Year
3
Years
5
Years
10
Years
$235
$821
$1,433
$3,085
Disciplined U.S. Equity Portfolio (formerly, Quantitative U.S. Large
Cap Core Equity Portfolio)
(Advisor Shares)
Fees and Expenses of the Portfolio
This table describes the fees and expenses that you may pay if
you buy, hold, and sell shares of the Portfolio. You may pay brokerage commissions and other fees to financial intermediaries which
are not reflected in the table and example below.
Advisor
Shares
Annual Portfolio Operating Expenses
(expenses that you
pay each year as a percentage of the value of your investment)
Management Fees
0.55%
Other Expenses
(includes 0.20% shareholder
servicing fees payable to Glenmede Trust)
0.31%
Total Annual Portfolio Operating Expenses
0.86%
Example
This Example is intended to help you compare the cost of investing in the
Portfolio’s Advisor Shares with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the
Portfolio for the time periods indicated and then hold or redeem all of your shares at the end of those periods. The Example also assumes
that your investment has a 5% return each year and that the Portfolio’s operating expenses remain the same. Although your actual
costs may be higher or lower, based on these assumptions your costs would be:
1
Year
3
Years
5
Years
10
Years
$88
$274
$477
$1,061
Disciplined U.S. Growth Equity Portfolio (formerly, Quantitative
U.S. Large Cap Growth Equity Portfolio)
(Advisor Shares)
Fees and Expenses of the Portfolio
This table describes the fees and expenses that you may pay if
you buy, hold, and sell shares of the Portfolio. You may pay brokerage commissions and other fees to financial intermediaries which
are not reflected in the table and example below.
Advisor
Shares
Annual Portfolio Operating Expenses
(expenses that you
pay each year as a percentage of the value of your investment)
Management Fees
0.55%
Other Expenses
(includes 0.20% shareholder
servicing fees payable to Glenmede Trust)
0.31%
Total Annual Portfolio Operating Expenses
0.86%
Example
This Example is intended to help you compare the cost of investing in the
Portfolio’s Advisor Shares with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the
Portfolio for the time periods indicated and then hold or redeem all of your shares at the end of those periods. The Example also assumes
that your investment has a 5% return each year and that the Portfolio’s operating expenses remain the same. Although your actual
costs may be higher or lower, based on these assumptions your costs would be:
1
Year
3
Years
5
Years
10
Years
$88
$274
$477
$1,061
Disciplined U.S. Value Equity Portfolio (formerly, Quantitative
U.S. Large Cap Value Equity Portfolio)
Fees and Expenses of the Portfolio
This table describes the fees and expenses that you may pay if you buy,
hold, and sell shares of the Portfolio. You may pay brokerage commissions and other fees to financial intermediaries which are not
reflected in the table and example below.
Annual Portfolio Operating Expenses
(expenses
that you pay each year as a percentage of the value of your investment)
Management Fees
0.55%
Other Expenses
(includes 0.20% shareholder
servicing fees payable to Glenmede Trust)
3.08%
Total Annual Portfolio Operating Expenses
3.63%
Fee Waivers and Expense Reimbursements1
2.78%
Net Expenses
0.85%
1 Glenmede
Investment Management LP (the “Advisor”) has contractually agreed to waive its
fees and/or reimburse expenses to the extent that the Portfolio’s annual total operating
expenses exceed 0.85% of the Portfolio’s average daily net assets (excluding Acquired
Fund fees and expenses, brokerage commissions, extraordinary items, interest and taxes).
The Advisor has contractually agreed to these waivers and/or reimbursements until at least
February 28, 2026 and may discontinue this arrangement at any time thereafter. This contractual
fee waiver agreement may not be terminated before February 28, 2026 without the approval
of The Glenmede Fund, Inc.’s (the “Fund”) Board of Directors (the “Board”).
Example
This Example is intended to help you compare the cost of investing in the
Portfolio with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the Portfolio for the time
periods indicated and then hold or redeem all of your shares at the end of those periods. The Example also assumes that your investment
has a 5% return each year and that the Portfolio’s operating expenses remain the same, taking into account the fee waiver in the
first year of each period. Although your actual costs may be higher or lower, based on these assumptions your costs would be:
1
Year
3
Years
5
Years
10
Years
$87
$853
$1,641
$3,706
Disciplined U.S. Small Cap Equity Portfolio (formerly, Quantitative
U.S. Small Cap Equity Portfolio)
Fees and Expenses of the Portfolio
This table describes the fees and expenses that you may pay if
you buy, hold, and sell shares of the Portfolio. You may pay brokerage commissions and other fees to financial intermediaries which
are not reflected in the table and example below.
Annual Portfolio
Operating Expenses
(expenses
that you pay each year as a percentage of the value of your investment)
Management Fees
0.55%
Other Expenses
(includes 0.20% shareholder
servicing fees payable to Glenmede Trust)
3.10%
Total Annual Portfolio Operating Expenses
3.65%
Fee Waivers and Expense Reimbursements1
2.80%
Net Expenses
0.85%
1 Glenmede
Investment Management LP (the “Advisor”) has contractually agreed to waive its
fees and/or reimburse expenses to the extent that the Portfolio’s annual total operating
expenses exceed 0.85% of the Portfolio’s average daily net assets (excluding Acquired
Fund fees and expenses, brokerage commissions, extraordinary items, interest and taxes).
The Advisor has contractually agreed to these waivers and/or reimbursements until at least
February 28, 2026 and may discontinue this arrangement at any time thereafter. This contractual
fee waiver agreement may not be terminated before February 28, 2026 without the approval
of The Glenmede Fund, Inc.’s (the “Fund”) Board of Directors (the “Board”).
Example
This Example is intended to help you compare the cost of investing
in the Portfolio with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the Portfolio for the
time periods indicated and then hold or redeem all of your shares at the end of those periods. The Example also assumes that your investment
has a 5% return each year and that the Portfolio’s operating expenses remain the same, taking into account the fee waiver in the
first year of each period. Although your actual costs may be higher or lower, based on these assumptions your costs would be:
1
Year
3
Years
5
Years
10
Years
$87
$857
$1,649
$3,723
Disciplined International Equity Portfolio (formerly, Quantitative
International Equity Portfolio)
Fees and Expenses of the Portfolio
This table describes the fees and expenses that you may pay if
you buy, hold, and sell shares of the Portfolio. You may pay brokerage commissions and other fees to financial intermediaries which
are not reflected in the table and example below.
Annual Portfolio
Operating Expenses
(expenses
that you pay each year as a percentage of the value of your investment)
Management Fees
0.75%
Other Expenses
(includes 0.25% shareholder
servicing fees payable to Glenmede Trust)
0.62%
Total Annual Portfolio Operating Expenses
1.37%
Fee Waivers and Expense Reimbursements1
0.37%
Net Expenses
1.00%
1 Glenmede
Investment Management LP (the “Advisor”) has contractually agreed to waive its
fees and/or reim