SEC Company Response from CCMI FUNDS (CIK 0000883496) — Oct 1, 2004
CCMI FUNDS (CIK 0000883496)
Date: Oct. 1, 2004 · CIK: 0000883496 · Accession: 0001035449-04-000471
AI Filing Summary & Sentiment
File numbers found in text: 811-6561
Letter
<DESCRIPTION>CCMI FUNDS THOMPSON BRUSSELS CINCINNATI CLEVELAND COLUMBUS DAYTON HINE NEW YORK WASHINGTON, D.C.
September 30, 2004
Electronic Transmission
Securities and Exchange Commission Public Filing Desk Judiciary Plaza 450 5th Street, N.W. Washington, D.C. 20549 Re: CCMI Funds, File Nos. 33-45753 and 811-6561
Ladies and Gentlemen:
On August 2, 2004, CCMI Funds (the "Trust") filed Post-Effective Amendment No. 23 to the Trust's Registration Statement (the "Amendment"). The Amendment was filed pursuant to Rule 485(a) promulgated under the Securities Act of 1933 with respect to the CCMI Bond Fund, the CCMI Equity Fund and the CCMI Tax-Exempt North Carolina Bond Fund (the "Funds"). This correspondence is filed to respond to comments and suggestions raised by the staff of the Securities and Exchange Commission (the "Staff").
1. With respect to the prospectus for the CCMI Bond Fund and the CCMI Equity Fund, the Staff requested that the footnote to the Fee Table be revised to disclose total distribution fees that could be paid by the Bond Fund if the distribution plan were activated by the Board of Trustees. The footnote has been revised in accordance with the Staff comment. This information was also added to the section of the prospectus titled "Distribution Plan and Shareholder Services Plan" in both prospectuses.
2. As requested, attached is a generic "Tandy" letter signed by an officer of the Trust.
If you have any questions concerning this response, please contact Donald S. Mendelsohn at (513) 352-6546.
Very truly yours,
/s/ Thompson Hine LLP
THOMPSON HINE LLP
JMS/kao cc: Keith O'Connell
<PAGE>
CCMI FUNDS
September 30, 2004
Electronic Transmission
Securities and Exchange Commission Public Filing Desk Judiciary Plaza 450 5th Street, N.W. Washington, D.C. 20549 Re: CCMI Funds, File Nos. 33-45753 and 811-6561
Ladies and Gentlemen:
On August 2, 2004, CCMI Funds (the "Trust") filed Post-Effective Amendment No. 23 to the Trust's Registration Statement (the "Amendment"). The staff of the Securities and Exchange Commission (the "Staff") commented on the Amendment, and requested that the Trust provide a statement in response to the generic "Tandy" letter.
The Trust hereby acknowledges that:
1. The Trust is responsible for the adequacy and accuracy of the disclosure in the Amendment;
2. Staff comments or changes to disclosure in response to Staff comments in the Amendment reviewed by the Staff do not foreclose the Commission from taking any action with respect to the Amendment; and
3. The Trust may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
CCMI FUNDS
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<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>ccmiletter093004.txt
<DESCRIPTION>CCMI FUNDS
<TEXT>
THOMPSON BRUSSELS CINCINNATI CLEVELAND COLUMBUS DAYTON
HINE NEW YORK WASHINGTON, D.C.
September 30, 2004
Electronic Transmission
Securities and Exchange Commission
Public Filing Desk
Judiciary Plaza
450 5th Street, N.W.
Washington, D.C. 20549
Re: CCMI Funds, File Nos. 33-45753 and 811-6561
Ladies and Gentlemen:
On August 2, 2004, CCMI Funds (the "Trust") filed Post-Effective
Amendment No. 23 to the Trust's Registration Statement (the "Amendment"). The
Amendment was filed pursuant to Rule 485(a) promulgated under the Securities Act
of 1933 with respect to the CCMI Bond Fund, the CCMI Equity Fund and the CCMI
Tax-Exempt North Carolina Bond Fund (the "Funds"). This correspondence is filed
to respond to comments and suggestions raised by the staff of the Securities and
Exchange Commission (the "Staff").
1. With respect to the prospectus for the CCMI Bond Fund and the CCMI
Equity Fund, the Staff requested that the footnote to the Fee Table be revised
to disclose total distribution fees that could be paid by the Bond Fund if the
distribution plan were activated by the Board of Trustees. The footnote has been
revised in accordance with the Staff comment. This information was also added to
the section of the prospectus titled "Distribution Plan and Shareholder Services
Plan" in both prospectuses.
2. As requested, attached is a generic "Tandy" letter signed by an
officer of the Trust.
If you have any questions concerning this response, please contact
Donald S. Mendelsohn at (513) 352-6546.
Very truly yours,
/s/ Thompson Hine LLP
THOMPSON HINE LLP
JMS/kao
cc: Keith O'Connell
<PAGE>
CCMI FUNDS
September 30, 2004
Electronic Transmission
Securities and Exchange Commission
Public Filing Desk
Judiciary Plaza
450 5th Street, N.W.
Washington, D.C. 20549
Re: CCMI Funds, File Nos. 33-45753 and 811-6561
Ladies and Gentlemen:
On August 2, 2004, CCMI Funds (the "Trust") filed Post-Effective
Amendment No. 23 to the Trust's Registration Statement (the "Amendment"). The
staff of the Securities and Exchange Commission (the "Staff") commented on the
Amendment, and requested that the Trust provide a statement in response to the
generic "Tandy" letter.
The Trust hereby acknowledges that:
1. The Trust is responsible for the adequacy and accuracy of the
disclosure in the Amendment;
2. Staff comments or changes to disclosure in response to Staff
comments in the Amendment reviewed by the Staff do not foreclose the Commission
from taking any action with respect to the Amendment; and
3. The Trust may not assert Staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
Very truly yours,
CCMI FUNDS
By: Freddie Jacobs, Jr.
--------------------------
Its: Secretary
--------------------------
JMS/kao
cc: Keith O'Connell
</TEXT>
</DOCUMENT>