SEC Company Response from NORTHERN FUNDS (CIK 0000916620) — Feb 23, 2021
NORTHERN FUNDS (CIK 0000916620)
Date: Feb. 23, 2021 · CIK: 0000916620 · Accession: 0001193125-21-052336
AI Filing Summary & Sentiment
File numbers found in text: 811-08236
Letter
Via Edgar Transmission Securities and Exchange Commission Washington, D.C. 20549 Attention: Jeff Long RE: Northern Funds (811-08236) Sarbanes-Oxley Review
Dear Mr. Long:
The following responds to the SEC Staff’s comments that you provided by telephone on January 26, 2021 regarding the review of the N-CSR filed by Northern Funds (the “Trust, and each series thereof, a “Fund”) for its fiscal year ended March 31, 2020.
For your convenience, the Staff’s comments are summarized below and each comment is followed by the Trust’s response.
1. Comment: Multi-Manager Global Listed Infrastructure Fund states that it is non-diversified. As of March 31, 2020, the Fund was operating as a diversified fund. If the Multi-Manager Global Listed Infrastructure Fund has been operating as diversified for the last three years, confirm it will receive shareholder approval for the switch to non-diversified status.
Response: The registrant confirms that, if the Multi-Manager Global Listed Infrastructure Fund operates as a diversified fund for a period of three years, the Multi-Manager Global Listed Infrastructure Fund will seek shareholder approval before operating as a non-diversified fund.
Regards,
/s/ Andrew E. Seaberg
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CORRESP
Faegre Drinker Biddle & Reath LLP
One Logan Square, Suite 2000
Philadelphia, PA 19103
215-988-1000 (Phone)
(215)
988-5757 (Facsimile)
www.faegredrinker.com
February 23, 2021
Via Edgar
Transmission
Securities and Exchange Commission
100
F Street, N.E.
Washington, D.C. 20549
Attention: Jeff Long
RE:
Northern Funds (811-08236)
Sarbanes-Oxley Review
Dear Mr. Long:
The following responds to the SEC Staff’s comments that you provided by telephone on January 26, 2021 regarding the review of the N-CSR filed by Northern Funds (the “Trust, and each series thereof, a “Fund”) for its fiscal year ended March 31, 2020.
For your convenience, the Staff’s comments are summarized below and each comment is followed by the Trust’s response.
1. Comment: Multi-Manager Global Listed Infrastructure Fund states that it is
non-diversified. As of March 31, 2020, the Fund was operating as a diversified fund. If the Multi-Manager Global Listed Infrastructure Fund has been operating as diversified for the last three years,
confirm it will receive shareholder approval for the switch to non-diversified status.
Response: The registrant confirms that, if the Multi-Manager Global Listed Infrastructure Fund
operates as a diversified fund for a period of three years, the Multi-Manager Global Listed Infrastructure Fund will seek shareholder approval before operating as a non-diversified fund.
Regards,
/s/ Andrew E. Seaberg
Andrew E. Seaberg
Copy to: Peter K. Ewing
Jose Del Real
Randal E. Rein
Kevin O’Rourke
Diana E. McCarthy