SEC Company Response from LEADER MUTUAL FUNDS (CIK 0000922637) — Jul 8, 2005
LEADER MUTUAL FUNDS (CIK 0000922637)
Date: July 8, 2005 · CIK: 0000922637 · Accession: 0000950152-05-005838
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Regions Morgan Keegan Select Funds
Morgan Keegan Select Fund, Inc.
50 North Front Street
Memphis, Tennessee 38103
July 8, 2005
Via EDGAR Correspondence & Regular Mail
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0505
Attention: Mr. Kevin Rupert, Staff Accountant (Mail Stop 05-05)
Office of Disclosure & Review
U.S. Securities and Exchange Commission
Dear Mr. Rupert:
On June 17, 2005, we received via a conference call comments (the "Comments") to
the Form N-CSR filed by the LEADER Mutual Funds (the "Trust") for the fiscal
year ended August 31, 2004. Effective February 18, 2005, the series of the
Trust reorganized into corresponding series of Regions Morgan Keegan Select
Funds and Morgan Keegan Select Fund, Inc.
You requested the written responses to the Comments be filed via EDGAR
correspondence within 21 days. This letter is intended to respond to the
Comments on behalf of the Trust and makes reference to sections of the Trust's
August 31, 2004 annual report as filed via EDGAR with the Securities and
Exchange Commission (the "SEC") on November 5, 2004.
To assist you with your review, we have preceded each of our responses with the
relative comment.
SEC COMMENT: WITHIN MANAGEMENT'S DISCUSSION OF FUND PERFORMANCE (MDFP), INCLUDE
THE GROWTH OF $10,000 FOR EACH SHARE CLASS.
Management's Response:
Item 22 (b) (7) (ii) (A) of N-1A requires a line graph comparing initial and
subsequent account values at the end of each of the most recently completed 10
fiscal years of the Fund. The Trust has disclosed the largest share class with
the longest performance history. Management believes this meets N-1A
requirements, but will consider adding line graphs for additional share classes
in future filings.
SEC COMMENT: WITHIN THE MDFP, ENSURE COMMENTARY DISCUSSES WHICH CLASSES OF
SHARES OUT PERFORMED THE BENCHMARK AND WHICH CLASSES OF SHARES UNDER PERFORMED
THE BENCHMARK.
Management's Response:
Within the MDFP of future filings, Management will add additional language to
the commentary or benchmark information to the performance tables.
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SEC COMMENT: WITHIN THE MDFP, INCLUDE THE AMOUNT OF THE CONTINGENT DEFERRED
SALES CHARGE.
Management's Response:
Effective February 18, 2005, all Investor B Shares of the Variable Funds
converted to Class A Shares of the same Fund and the Trust terminated the
Investor B Shares. There are no longer any classes that have a contingent
deferred sales charge. This comment does not apply to future filings.
SEC COMMENT: WITHIN THE LEADER TAX-EXEMPT BOND FUND MDFP, UPDATE THE OBJECTIVE
TO ALSO INCLUDE INCOME EXEMPT FROM ALTERNATIVE MINIMUM TAX ("AMT").
Management's Response:
The Registrant notes in the discussion of the Fund's Principal Investment
Strategies, that certain investments are noted as being subject to the
alternative minimum tax. Furthermore it is a strategy of the Fund to invest up
to 20% of its assets in securities that may be subject to the alternative
minimum tax. In future filings Management will add language to specifically
discuss the Fund's Principal Investment Strategies relating to alternative
minimum tax.
SEC COMMENT: WITHIN THE LEADER TAX-EXEMPT BOND FUND MDFP, UPDATE THE COMMENTARY
TO EXPLAIN THE DIFFERENTIAL IN EXPENSE RATIO.
Management's Response:
Management will include additional language to clarify the differential in
expense ratio or remove this language from future filings.
SEC COMMENT: WITHIN THE MDFP FOR LEADER TAX-EXEMPT MONEY MARKET FUND AND LEADER
MONEY MARKET FUND, REVIEW WORDING OF SEVEN-DAY YIELD COMMENTARY.
Management's Response:
The EDGAR version contained some formatting differences from the printed report.
Management will review future filings more carefully to ensure formatting
differences are corrected prior to filing. The printed report was as follows,
"The seven-day yield(1) on the Fund's Institutional Shares was...."
SEC COMMENT: IN THE NOTES TO FINANCIAL STATEMENTS, ENSURE DESCRIPTION OF WAIVER
AGREEMENT WITHIN THE RELATED PARTY TRANSACTIONS IS CLEAR.
Management's Response:
Management will ensure that the commentary preceding the Annual Fee Before
Voluntary Reduction and Annual Fee After Voluntary Reduction sufficiently
discloses the description of the waiver arrangement and the calculation
methodology in future filings.
In connection with the Comments, our responses thereto, and all future filings
of Form N-CSR and Form N-Q, as appropriate, management of the Trust acknowledges
that:
- the Trust is responsible for the adequacy and accuracy of the
disclosure in the filings;
- staff comments or changes to disclosure in response to staff comments
in the filings reviewed by the staff do not foreclose the Commission
from taking any action with respect to the filing; and
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- 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.
We trust that this information will be of assistance. Please contact the
undersigned at (901) 524-4140 with any questions.
Respectfully submitted,
/s/ Joseph C. Weller
Joseph C. Weller
Treasurer
Regions Morgan Keegan Select Funds
Morgan Keegan Select Fund, Inc.
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