Correspondence 0001104659-25-040072 from M FUND INC (CIK 0000948258)
M FUND INC (CIK 0000948258)
Date: April 28, 2025 · CIK: 0000948258 · Accession: 0001104659-25-040072
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 811-09082
Letter
Brian F. Link, Esq.
Managing Director and Managing Counsel
T +1-617-662-1504
Brian.link@statestreet.com
State Street Corporation
One Congress Street
Boston, MA 02114-2016
statestreet.com
April 28, 2025
VIA EDGAR CORRESPONDENCE FILING
United States Securities and Exchange Commission
Division of Investment Management, Disclosure Review Office
100 F Street, N.E.
Washington, D.C. 20549-8626
Attn: Mark Cowan
Re: M Fund, Inc. (Registration No. 033-95472/811-09082)
Response to Examiner Comments on Post-Effective
Amendment No. 48
Ladies and Gentlemen:
This letter responds to your comments provided via telephone on March 14, 2025 to Post-Effective Amendment No. 48 to the Registration Statement on Form N-1A of M Fund, Inc. (the “Registrant”) filed on February 20, 2025.
1. Comment: The Registrant discloses that the M Large Cap Growth Fund’s (the “Fund”) sub-adviser utilizes a large-cap growth approach by selecting most of its investments from companies listed in the Russell 1000 Growth Index. The Registrant discloses the market cap range of the Russell 1000 Growth Index. Please clarify in disclosure what the Fund considers “large-cap.”
Response: The Registrant has revised disclosure as requested.
2. Comment: The Registrant states that “the Fund may, from time to time, have large allocations to certain broad market sectors, such as technology, consumer discretionary and healthcare. Given that
the Fund has a fundamental policy not to concentrate, please clarify that those large allocations will not be greater than 25% of the Fund’s assets.
Response: The Registrant confirms that while the Fund may have large allocations to certain sectors, it will not invest greater than 25% of its assets in any one sector.
3. Comment: The Fund states that “risk is controlled through diversification constraints which limit exposure to individual companies as well as groups of correlated companies. Please confirm that this disclosure is not in conflict with the Fund’s non-diversification policy.
Response: The Registrant confirms that while the Fund intends to maintain a diversified portfolio that includes numerous individual companies as well as groups of correlated companies, the Fund has elected to be a non-diversified fund and it intends to operate accordingly.
4. Comment: Please consider updating the Market Disruption Risk in light of certain events, including recent changes in global trade policy.
Response: The Registrant has revised disclosure as requested.
5. Comment: Consider adding a risk factor related to the Fund’s active trading.
Response: The Registrant has revised disclosure as requested.
6. Comment: When disclosing the Fund’s secondary benchmark index, consider including disclosure regarding the purpose for including a secondary benchmark in the narrative prior to the performance table, rather than as a footnote to the performance table.
Response: The Registrant has revised disclosure as requested.
7. Comment: The Registrant states that “The performance reflects the performance results obtained under a different sub-adviser that used a different investment strategy. Had the current sub-adviser and investment strategies been in place prior to December 31, 2024, the performance results may have been different.” Because the new portfolio manager begins after December 31, 2024 and outside the reporting period of the performance table, consider revising this disclosure.
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Response: The Registrant has revised disclosure as requested.
8. Comment: Please disclose the name of the Fund’s broad-based index.
Response: The Registrant has revised disclosure as requested.
* * * * * *
Please direct any further comments or questions regarding this response letter to the undersigned at (617) 821-5257.
Very truly yours,
/s/ Brian F. Link
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Brian F. Link, Esq.
Managing Director and Managing Counsel
T +1-617-662-1504
Brian.link@statestreet.com
State Street Corporation
One Congress Street
Boston, MA 02114-2016
statestreet.com
April 28, 2025
VIA EDGAR CORRESPONDENCE FILING
United States Securities and Exchange Commission
Division of Investment Management, Disclosure Review Office
100 F Street, N.E.
Washington, D.C. 20549-8626
Attn: Mark Cowan
Re:
M Fund, Inc. (Registration No. 033-95472/811-09082)
Response to Examiner Comments on Post-Effective
Amendment No. 48
Ladies and Gentlemen:
This letter responds to your comments provided
via telephone on March 14, 2025 to Post-Effective Amendment No. 48 to the Registration Statement on Form N-1A of M Fund, Inc. (the “Registrant”)
filed on February 20, 2025.
1. Comment: The Registrant discloses that the M Large Cap Growth Fund’s (the “Fund”)
sub-adviser utilizes a large-cap growth approach by selecting most of its investments from companies listed in the Russell 1000 Growth
Index. The Registrant discloses the market cap range of the Russell 1000 Growth Index. Please clarify in disclosure what the Fund considers
“large-cap.”
Response: The Registrant has
revised disclosure as requested.
2.
Comment: The Registrant states that “the Fund may, from time to time, have large allocations to certain broad market sectors, such as technology, consumer discretionary and healthcare. Given that
the Fund has a fundamental
policy not to concentrate, please clarify that those large allocations will not be greater than 25% of the Fund’s assets.
Response: The Registrant confirms
that while the Fund may have large allocations to certain sectors, it will not invest greater than 25% of its assets in any one sector.
3. Comment: The Fund states that “risk is controlled through diversification constraints
which limit exposure to individual companies as well as groups of correlated companies. Please confirm that this disclosure is not in
conflict with the Fund’s non-diversification policy.
Response:
The Registrant confirms that while the Fund intends to maintain a diversified portfolio that includes numerous individual
companies as well as groups of correlated companies, the Fund has elected to be a non-diversified fund and it intends to operate
accordingly.
4. Comment: Please consider updating the Market Disruption Risk in light of certain events,
including recent changes in global trade policy.
Response: The Registrant
has revised disclosure as requested.
5. Comment: Consider adding a risk factor related to the Fund’s active trading.
Response: The
Registrant has revised disclosure as requested.
6. Comment: When disclosing the Fund’s secondary benchmark index, consider including disclosure
regarding the purpose for including a secondary benchmark in the narrative prior to the performance table, rather than as a footnote to
the performance table.
Response: The
Registrant has revised disclosure as requested.
7. Comment: The Registrant states that “The
performance reflects the performance results obtained under a different sub-adviser that used a different investment strategy. Had the
current sub-adviser and investment strategies been in place prior to December 31, 2024, the performance results may have been different.”
Because the new portfolio manager begins after December 31, 2024 and outside the reporting period of the
performance table, consider revising this disclosure.
Page
2
Response: The
Registrant has revised disclosure as requested.
8. Comment: Please disclose the name of the Fund’s broad-based index.
Response: The
Registrant has revised disclosure as requested.
* * * * * *
Please direct
any further comments or questions regarding this response letter to the undersigned at (617) 821-5257.
Very truly yours,
/s/ Brian F. Link
Brian F. Link
Page
3