Correspondence 0000894189-24-005578 from Jensen Quality Growth Fund Inc (CIK 0000887215)
Jensen Quality Growth Fund Inc (CIK 0000887215)
Date: Sept. 12, 2024 · CIK: 0000887215 · Accession: 0000894189-24-005578
AI Filing Summary & Sentiment
File numbers found in text: 811-066531
Letter
VIA EDGAR TRANSMISSION United States Securities and Exchange Commission Division of Investment Management Re: Jensen Quality Growth Fund Inc (the “Fund”) Securities Act Registration No: 033-47508 Investment Company Act Registration No: 811-066531 The Jensen Quality Growth Fund Inc (S000004905)
Dear Ms. O’Neal,
This correspondence responds to the oral comments the Fund received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on September 4, 2024 with respect to the Preliminary Proxy Statement filed by the Fund on August 26, 2024.
For your convenience in reviewing the Fund’s responses, the Staff’s comments are included in bold typeface immediately followed by the Fund’s responses. Capitalized terms not otherwise defined in this response letter have the meaning set forth in the Definitive Proxy Statement.
General Comments
1.Staff Comment: Please add the cost of the solicitation in the applicable areas (the FAQ and the body of the proxy).
Response: The Fund responds by making the requested revision.
2. Staff Comment: On page 4 of the Q&A, in the second to last sentence of the paragraph at the top of the page, please revise the sentence to read: Broker non-votes occur when proxies returned by beneficial owners of shares held by brokers for shares held by brokers do not include voting instructions.
Response: The Fund responds by making the requested revision.
* * * * * *
If you have any additional questions or require further information, please contact Jay Fitton at (513) 520-5925.
Sincerely,
/s/ [...]
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CORRESP 1 filename1.htm Document Please note that this letter and other documents are in draft form, and in no way reflect the Fund’s or Fund management’s final intent with respect to the filing discussed herein. U.S. Bank Global Fund Services 615 East Michigan Street Milwaukee, Wisconsin 53202 September [...], 2024 VIA EDGAR TRANSMISSION Ms. Deborah L. O’Neal United States Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Re: Jensen Quality Growth Fund Inc (the “Fund”) Securities Act Registration No: 033-47508 Investment Company Act Registration No: 811-066531 The Jensen Quality Growth Fund Inc (S000004905) Dear Ms. O’Neal, This correspondence responds to the oral comments the Fund received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on September 4, 2024 with respect to the Preliminary Proxy Statement filed by the Fund on August 26, 2024. For your convenience in reviewing the Fund’s responses, the Staff’s comments are included in bold typeface immediately followed by the Fund’s responses. Capitalized terms not otherwise defined in this response letter have the meaning set forth in the Definitive Proxy Statement. General Comments 1.Staff Comment: Please add the cost of the solicitation in the applicable areas (the FAQ and the body of the proxy). Response: The Fund responds by making the requested revision. 2. Staff Comment: On page 4 of the Q&A, in the second to last sentence of the paragraph at the top of the page, please revise the sentence to read: Broker non-votes occur when proxies returned by beneficial owners of shares held by brokers for shares held by brokers do not include voting instructions. Response: The Fund responds by making the requested revision. * * * * * * 1 If you have any additional questions or require further information, please contact Jay Fitton at (513) 520-5925. Sincerely, /s/ [...] Robert D. McIver President The Jensen Quality Growth Fund Inc. 2