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SEC Company Response from CREDIT SUISSE GLOBAL FIXED INCOME FUND INC (CIK 0000866265) — Apr 29, 2005

CREDIT SUISSE GLOBAL FIXED INCOME FUND INC (CIK 0000866265)
Date: April 29, 2005 · CIK: 0000866265 · Accession: 0000891804-05-001320

AI Filing Summary & Sentiment

File numbers found in text: 811-06143

Date
April 29, 2005
Author
Dianne E. O'Donnell
Form
CORRESP
Company
CREDIT SUISSE GLOBAL FIXED INCOME FUND INC (CIK 0000866265)

Letter

RE: Credit Suisse Global Fixed Income Fund, Inc. (the "Fund") Securities Act File No. 33-36066, Investment Company Act File No. 811-06143 Post-Effective Amendment No. 21

Letterhead of Willkie Farr & Gallagher LLP

VIA EDGAR

April 29, 2005

Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549

Ladies and Gentlemen:

On behalf of the Fund, I hereby transmit for filing pursuant to Rule 485(a) of the Securities Act of 1933, as amended (the "1933 Act"), Post-Effective Amendment No. 21 (the "Amendment") to the Fund's Registration Statement under the 1933 Act and the Investment Company Act of 1940, as amended (the "1940 Act").

The Amendment has been marked to show changes in response to the comments of the Commission's staff (the "Staff") on Amendment No. 20 to the Fund's Registration Statement that were provided by Christian T. Sandoe of the Staff in a telephone conversation with the undersigned on April 19, 2005. For the convenience of the Staff, the substance of those comments has been set forth below. The Fund's responses to a particular comment are set out immediately under the restated comment. Page references in the Fund's responses are to the Fund's revised Class A and Class C Prospectus (the "Prospectus") or the revised Statement of Additional Information (the "SAI") filed as part of Amendment No. 21. Please note that conforming changes have also been made to the Fund's Common Class Prospectus.

PROSPECTUS:

KEY POINTS--GOAL AND PRINCIPAL STRATEGIES (P. 4)

1. Comment: If non-investment grade investments (such as junk bonds) are part of the Fund's principal strategy, please note under "principal strategies."

Response: While the limit on the Fund's ability to invest in non-investment grade securities is 35% of net Fund assets, historically the Fund has invested in emerging markets only to a limited extent. As of March 31, 2005, the Fund has less than 1% of its investments in non-investment grade securities. This percentage is consistent with the Fund's historical practice. The Fund does not believe that that level of investment rises to the level of a principal strategy so is not revising this section.

2. Comment: The Fund should disclose its maturity policy, if it has one.

<PAGE>

Securities and Exchange Commission April 29, 2005 Page 2

Response: The Fund does not have a maturity policy.

3. Comment: The Fund's description of "credit risk" uses the term "counterparty to a contract," which infers that the Fund invests in swaps.

Response: As swaps are not a principal investment strategy, "credit risk" has been revised to remove reference to "counterparties to a contract." See page 4 of the Prospectus.

4. Comment: The Fund should add the risk of investing in emerging markets to its risk/return disclosure if such investments constitute a significant portion of the Fund's assets.

Response: While there is no limit on the Fund's ability to invest in emerging markets, historically the Fund has invested in emerging markets only to a limited extent. According to the Fund's portfolio holdings as of March 31, 2005, as disclosed on the Fund's website, www.csam.com/us, the Fund had approximately 2% of its assets invested in emerging markets. This percentage is consistent with the Fund's historical practice. The Fund does not believe that this level of investment rises to the level of a principal risk so is not revising this section.

5. Comment: The Fund should add the risk of investing in government and mortgage backed securities to its risk/return disclosure if such investments constitute a significant portion of the Fund's assets.

Response: The Fund does have significant investments in such securities and will include disclosure stating that the securities are not backed by the full faith and credit of the U.S. government. See page 13 of the Prospectus.

MORE ABOUT RISK (P. 15)

6. Comment: The last sentence of the first paragraph states that this section describes "other risks" that may affect the Fund. As this section appears to include both principal and non-principal risks, please identify in this section which risks are principal and which risks are non-principal.

Response: As discussed with Mr. Sandoe of the Staff, this change is not being made in this Prospectus, but will be made in the Fund's next annual update and those of all other Credit Suisse Funds.

STATEMENT OF ADDITIONAL INFORMATION

MANAGEMENT OF THE FUND--DISCLOSURE OF PORTFOLIO HOLDINGS (PP. 49-50)

<PAGE>

Securities and Exchange Commission April 29, 2005 Page 3

7. Comment: Discuss the role of the portfolio manager on the team and the relationship between each portfolio manager's role and the roles of others on the team.

Response: We have revised the disclosure to include such a discussion. Please see page 49 of the SAI.

8. Comment: Since performance is taken into account in determining a portfolio manager's bonus, please describe how performance is considered.

Response: We have added disclosure to the SAI with respect to factors considered in determining the discretionary bonus, which include, but are not limited to performance, and include assets held in the Fund and other accounts managed by the portfolio managers, business growth, teamwork, management, corporate citizenship, etc.

9. Comment: Please describe the meaning of the term "phantom shares."

Response: We have revised the disclosure to include such a definition. Please see page 49 of the SAI.

10. Comment: Please clarify whether the base salary is "fixed."

Response: The base salary is fixed and we have revised the disclosure to read "fixed base salary." See page 49 of the SAI.

We hope the Staff finds this letter and the revisions in the Amendment responsive to the Staff's concerns.

On behalf of the Fund, we hereby acknowledge that that the disclosure in the Amendment is the Fund's responsibility. On behalf of the Fund, we hereby acknowledge that the Staff's comments do not foreclose the Commission from taking any action with respect to the Amendment and, on behalf of the Fund, we hereby represent that the Fund will not assert the Staff's comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

On behalf of the Fund, we further acknowledge that the Staff's comments do not relieve the Fund from its full responsibility for the adequacy and accuracy of the disclosures in the filing.

We also request that you grant acceleration for effectiveness on April 29, 2005.

Any questions or comments on the Amendment should be directed to the undersigned at (212) 728-8558.

Very truly yours,
/s/ Dianne E. O'Donnell
-----------------------
Dianne E. O'Donnell

Show Raw Text
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                   Letterhead of Willkie Farr & Gallagher LLP

VIA EDGAR

April 29, 2005

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

   RE: Credit Suisse Global Fixed Income Fund, Inc. (the "Fund")
       Securities Act File No. 33-36066, Investment Company Act
       File No. 811-06143
       Post-Effective Amendment No. 21

Ladies and Gentlemen:

On behalf of the Fund, I hereby transmit for filing pursuant to Rule 485(a) of
the Securities Act of 1933, as amended (the "1933 Act"), Post-Effective
Amendment No. 21 (the "Amendment") to the Fund's Registration Statement under
the 1933 Act and the Investment Company Act of 1940, as amended (the "1940
Act").

The Amendment has been marked to show changes in response to the comments of the
Commission's staff (the "Staff") on Amendment No. 20 to the Fund's Registration
Statement that were provided by Christian T. Sandoe of the Staff in a telephone
conversation with the undersigned on April 19, 2005. For the convenience of the
Staff, the substance of those comments has been set forth below. The Fund's
responses to a particular comment are set out immediately under the restated
comment. Page references in the Fund's responses are to the Fund's revised Class
A and Class C Prospectus (the "Prospectus") or the revised Statement of
Additional Information (the "SAI") filed as part of Amendment No. 21. Please
note that conforming changes have also been made to the Fund's Common Class
Prospectus.

PROSPECTUS:

KEY POINTS--GOAL AND PRINCIPAL STRATEGIES (P. 4)

1.   Comment: If non-investment grade investments (such as junk bonds) are part
     of the Fund's principal strategy, please note under "principal strategies."

     Response: While the limit on the Fund's ability to invest in non-investment
     grade securities is 35% of net Fund assets, historically the Fund has
     invested in emerging markets only to a limited extent. As of March 31,
     2005, the Fund has less than 1% of its investments in non-investment grade
     securities. This percentage is consistent with the Fund's historical
     practice. The Fund does not believe that that level of investment rises to
     the level of a principal strategy so is not revising this section.

2.   Comment: The Fund should disclose its maturity policy, if it has one.

<PAGE>

Securities and Exchange Commission
April 29, 2005
Page 2

     Response: The Fund does not have a maturity policy.

3.   Comment: The Fund's description of "credit risk" uses the term
     "counterparty to a contract," which infers that the Fund invests in swaps.

     Response: As swaps are not a principal investment strategy, "credit risk"
     has been revised to remove reference to "counterparties to a contract." See
     page 4 of the Prospectus.

4.   Comment: The Fund should add the risk of investing in emerging markets to
     its risk/return disclosure if such investments constitute a significant
     portion of the Fund's assets.

     Response: While there is no limit on the Fund's ability to invest in
     emerging markets, historically the Fund has invested in emerging markets
     only to a limited extent. According to the Fund's portfolio holdings as of
     March 31, 2005, as disclosed on the Fund's website, www.csam.com/us, the
     Fund had approximately 2% of its assets invested in emerging markets. This
     percentage is consistent with the Fund's historical practice. The Fund does
     not believe that this level of investment rises to the level of a principal
     risk so is not revising this section.

5.   Comment: The Fund should add the risk of investing in government and
     mortgage backed securities to its risk/return disclosure if such
     investments constitute a significant portion of the Fund's assets.

     Response: The Fund does have significant investments in such securities and
     will include disclosure stating that the securities are not backed by the
     full faith and credit of the U.S. government. See page 13 of the
     Prospectus.

     MORE ABOUT RISK (P. 15)

6.   Comment: The last sentence of the first paragraph states that this section
     describes "other risks" that may affect the Fund. As this section appears
     to include both principal and non-principal risks, please identify in this
     section which risks are principal and which risks are non-principal.

     Response: As discussed with Mr. Sandoe of the Staff, this change is not
     being made in this Prospectus, but will be made in the Fund's next annual
     update and those of all other Credit Suisse Funds.

STATEMENT OF ADDITIONAL INFORMATION

MANAGEMENT OF THE FUND--DISCLOSURE OF PORTFOLIO HOLDINGS (PP. 49-50)

<PAGE>

Securities and Exchange Commission
April 29, 2005
Page 3

7.   Comment: Discuss the role of the portfolio manager on the team and the
     relationship between each portfolio manager's role and the roles of others
     on the team.

     Response: We have revised the disclosure to include such a discussion.
     Please see page 49 of the SAI.

8.   Comment: Since performance is taken into account in determining a portfolio
     manager's bonus, please describe how performance is considered.

     Response: We have added disclosure to the SAI with respect to factors
     considered in determining the discretionary bonus, which include, but are
     not limited to performance, and include assets held in the Fund and other
     accounts managed by the portfolio managers, business growth, teamwork,
     management, corporate citizenship, etc.

9.   Comment: Please describe the meaning of the term "phantom shares."

     Response: We have revised the disclosure to include such a definition.
     Please see page 49 of the SAI.

10.  Comment: Please clarify whether the base salary is "fixed."

     Response: The base salary is fixed and we have revised the disclosure to
     read "fixed base salary." See page 49 of the SAI.

We hope the Staff finds this letter and the revisions in the Amendment
responsive to the Staff's concerns.

On behalf of the Fund, we hereby acknowledge that that the disclosure in the
Amendment is the Fund's responsibility. On behalf of the Fund, we hereby
acknowledge that the Staff's comments do not foreclose the Commission from
taking any action with respect to the Amendment and, on behalf of the Fund, we
hereby represent that the Fund will not assert the Staff's comments as a defense
in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

On behalf of the Fund, we further acknowledge that the Staff's comments do not
relieve the Fund from its full responsibility for the adequacy and accuracy of
the disclosures in the filing.

We also request that you grant acceleration for effectiveness on April 29, 2005.

Any questions or comments on the Amendment should be directed to the undersigned
at (212) 728-8558.

Very truly yours,

/s/ Dianne E. O'Donnell
-----------------------
Dianne E. O'Donnell

cc:  Christian Sandoe, Division of Investment Management
     J. Kevin Gao, Esq.
     Rose F. DiMartino, Esq.

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