SEC Company Response from M FUND INC (CIK 0000948258) — Apr 23, 2020
M FUND INC (CIK 0000948258)
Date: April 23, 2020 · CIK: 0000948258 · Accession: 0001104659-20-050356
AI Filing Summary & Sentiment
File numbers found in text: 811-09082
Letter
Re: M Fund, Inc. (Registration No. 033-95472/811-09082) Response to Examiner Comments on Post-Effective Amendment No. 41
April 23, 2020
VIA EDGAR CORRESPONDENCE
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Attention: Ms. Yoon Choo
Dear: Ms. Choo:
This letter responds to your comments provided via telephone on April 22, 2020 to Post-Effective Amendment No. 41 to the Registration Statement on Form N-1A of M Fund, Inc. (the “Registrant”) filed on April 17, 2020.
1. Comment: Because large capitalization investing risk is a principal investment risk of the M International Equity Fund, please include investing in large capitalization securities in the Fund’s principal investment strategies.
Response: Large Capitalization Risk is not a principal risk of the Fund. The Registrant has revised the disclosure to remove Large Capitalization Risk from the Fund.
2. Comment: Please add to the M International Equity Fund’s principal investment strategy that the Fund may invest up to 40% of its total assets in emerging markets.
Response: The Registrant has revised the disclosure as requested.
3. Comment: The M Large Cap Growth Fund references rights and warrants in its principal investment strategies section. Please include rights and warrants as risk factors in the Fund’s principal investment risk section.
Response: The Registrant has revised the disclosure as requested.
4. Comment: The M Large Cap Growth Fund invests in a small number of securities. Please include in the Fund’s principal investment risks the risks of investing in a small number of securities.
Response: The Registrant has revised the disclosure as requested.
5. Comment: Please revise the tax information section to include “expects” when disclosing that each Fund “expects” to qualify for taxation as a regulated investment company under subchapter M of chapter 1 of the Internal Revenue Code of 1986 for each taxable year.
Response: The Registrant has revised the disclosure as requested.
6. Comment: Please add to the Principal Risks of Investing in the Funds table the risks associated with investing in rights and warrants and risks associated with investing in a small number of securities.
Response: The Registrant has revised the disclosure as requested.
7. Comment: Under Foreign Securities and Currencies Risk in the statutory prospectus, the M International Equity Fund states that it does not hedge for currency risk. Please include any other Funds that do not hedge for currency risk.
Response: The Registrant has revised the disclosure to include the M Large Cap Growth Fund and M Capital Appreciation Fund.
8. Comment: Consider whether Growth Securities Risk is a principal investment risk of the M Large Cap Value Fund. If it is not please remove the Fund in the description of Growth Securities Risk.
Response: The Registrant has revised the disclosure to remove Growth Securities Risk from the Fund.
9. Comment: Since two Board approvals are referenced under the description of the basis for the Board of Directors’ approvals of the advisory and sub-advisory contracts, consider including the term of each Board approval.
Response: The Registrant has revised the disclosure as requested.
10. Comment: Under “Interpretive Rules,” please revise the disclosure to include “borrowing by a Fund” from the scenarios that are deemed to be a violation and add “except with respect to borrowings” when disclosing that market fluctuations that cause a Fund to exceed or fall short of a stated limitation will not be deemed to cause the Fund to violate a restriction.
Response: The Registrant has revised the disclosure as requested.
We trust that the foregoing is responsive to your comments. Please feel free to contact the undersigned at 617-662-1504 if you have any questions.
Sincerely yours,
/s/ Brian F. Link
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CORRESP 1 filename1.htm April 23, 2020 VIA EDGAR CORRESPONDENCE Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attention: Ms. Yoon Choo Re: M Fund, Inc. (Registration No. 033-95472/811-09082) Response to Examiner Comments on Post-Effective Amendment No. 41 Dear: Ms. Choo: This letter responds to your comments provided via telephone on April 22, 2020 to Post-Effective Amendment No. 41 to the Registration Statement on Form N-1A of M Fund, Inc. (the “Registrant”) filed on April 17, 2020. 1. Comment: Because large capitalization investing risk is a principal investment risk of the M International Equity Fund, please include investing in large capitalization securities in the Fund’s principal investment strategies. Response: Large Capitalization Risk is not a principal risk of the Fund. The Registrant has revised the disclosure to remove Large Capitalization Risk from the Fund. 2. Comment: Please add to the M International Equity Fund’s principal investment strategy that the Fund may invest up to 40% of its total assets in emerging markets. Response: The Registrant has revised the disclosure as requested. 3. Comment: The M Large Cap Growth Fund references rights and warrants in its principal investment strategies section. Please include rights and warrants as risk factors in the Fund’s principal investment risk section. Response: The Registrant has revised the disclosure as requested. 4. Comment: The M Large Cap Growth Fund invests in a small number of securities. Please include in the Fund’s principal investment risks the risks of investing in a small number of securities. Response: The Registrant has revised the disclosure as requested. 5. Comment: Please revise the tax information section to include “expects” when disclosing that each Fund “expects” to qualify for taxation as a regulated investment company under subchapter M of chapter 1 of the Internal Revenue Code of 1986 for each taxable year. Response: The Registrant has revised the disclosure as requested. 6. Comment: Please add to the Principal Risks of Investing in the Funds table the risks associated with investing in rights and warrants and risks associated with investing in a small number of securities. Response: The Registrant has revised the disclosure as requested. 7. Comment: Under Foreign Securities and Currencies Risk in the statutory prospectus, the M International Equity Fund states that it does not hedge for currency risk. Please include any other Funds that do not hedge for currency risk. Response: The Registrant has revised the disclosure to include the M Large Cap Growth Fund and M Capital Appreciation Fund. 8. Comment: Consider whether Growth Securities Risk is a principal investment risk of the M Large Cap Value Fund. If it is not please remove the Fund in the description of Growth Securities Risk. Response: The Registrant has revised the disclosure to remove Growth Securities Risk from the Fund. 9. Comment: Since two Board approvals are referenced under the description of the basis for the Board of Directors’ approvals of the advisory and sub-advisory contracts, consider including the term of each Board approval. Response: The Registrant has revised the disclosure as requested. 10. Comment: Under “Interpretive Rules,” please revise the disclosure to include “borrowing by a Fund” from the scenarios that are deemed to be a violation and add “except with respect to borrowings” when disclosing that market fluctuations that cause a Fund to exceed or fall short of a stated limitation will not be deemed to cause the Fund to violate a restriction. Response: The Registrant has revised the disclosure as requested. We trust that the foregoing is responsive to your comments. Please feel free to contact the undersigned at 617-662-1504 if you have any questions. Sincerely yours, /s/ Brian F. Link Brian F. Link