SEC Company Response from DRIEHAUS MUTUAL FUNDS (CIK 0001016073) — Sep 11, 2025
DRIEHAUS MUTUAL FUNDS (CIK 0001016073)
Date: Sept. 11, 2025 · CIK: 0001016073 · Accession: 0001398344-25-018038
AI Filing Summary & Sentiment
File numbers found in text: 811-07655
Letter
Via Edgar Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Driehaus Mutual Funds (File No. 811-07655) (the “Registrant”)
Dear Ms. Fettig:
On behalf of the Registrant, this letter is in response to the comments you relayed during our telephone conference on August 27, 2025 regarding the Registrant’s Forms N-CSR and N-CEN for the period ended December 31, 2024. Any changes made in response to these comments will be reflected in future filings.
Form N-CSR
1. Comment: With respect to the tailored shareholder reports, Form N-1A, Item 27A(d)(2), Instruction 8 requires disclosures regarding a change in index from the one used for the preceding reporting period. For those Funds that had a benchmark change, please explain supplementally the reason(s) for the changes, and for any future index changes, please include the required disclosures in the tailored shareholder reports.
Response: As disclosed in the Funds’ prospectus dated April 30, 2024, for those Funds that changed their index, they did so to show the returns of an index that may be considered more broadly representative of the overall applicable securities market. Going forward the Registrant will include the required disclosures regarding any index changes in the next tailored shareholder report.
2. Comment: With respect to the Schedule of Investments for Driehaus Event Driven Fund (page 35), please confirm that the value for the Royal Caribbean Cruises holding is correct at $0.
Response: The Royal Caribbean Cruises holding was called on August 13, 2024. The holding was previously part of a corporate bond basket of securities that was renewed on November 1, 2024 and thus should not have been included as part of the Schedule of Investments as of December 31, 2024.
North LaSalle Street | Chicago, Illinois 60601 | T +1 312 609 7500 | F +1 312 609 5005
Vedder Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, Vedder Price Pte. Ltd., which operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.
Ms. Christina DiAngelo Fettig
September 11, 2025
Page 2
3. Comment: In the Securities Valuation section in the Notes to Financial Statements, please disclose how investments in money market funds are valued.
Response: In the Registrant’s Form N-CSR as of December 31, 2025, the Registrant will disclose that investments in money market funds are valued at the funds’ net asset value.
4. Comment: In the Significant Accounting Policies section in the Notes to Financial Statements, please disclose the method used to allocate income and expenses and realized and unrealized capital gains and losses to each class of shares as required by FASB ASC 946-235-50-2.
Response: In the Registrant’s Form N-CSR as of December 31, 2025, the Registrant will provide such disclosure.
Form N-CEN
5. Comment: With respect to Item C.20.a (line of credit), please respond on a per Fund basis as required by the Form.
Response: The Registrant will make this change going forward.
6. Comment: Please respond to Items C.20.b (interfund lending) and C.20.c (interfund borrowing).
Response: The Registrant will include responses to these items going forward.
Form N-CSR/Website Disclosure
7. Comment: On the Registrant’s website, with respect to the information included at the link Annual Financial Statements and Additional Information, the information responsive to Form N-CSR, Items 8, 9 and 11 differs from the text filed on Form N-CSR; the disclosure should be accurate and consistent. In addition, although it was included in the Registrant’s Form N-CSR filing, the information responsive to Form N-CSR, Item 10 is not included on the website. Also consider disclosing on the Registrant’s website a parenthetical reference to the Form N-CSR item on the website; for example, Statement Regarding Basis for Approval of Investment Advisory Contract (Form N-CSR, Item 11).
Response: In the Registrant’s Form N-CSR as of December 31, 2025, the Registrant will make such disclosures consistent and include Item 10 on the website.
* * *
Ms. Christina DiAngelo Fettig
September 11, 2025
Page 3
If you have any questions regarding these responses, please call me at (312) 609-7616.
Very truly yours,
/s/ Renee M. Hardt
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CORRESP
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filename1.htm
Chicago
New York
Washington, DC
London
San Francisco
Los Angeles
Singapore
Dallas
Miami
vedderprice.com
Renee M. Hardt
Shareholder
+1 (312) 609 7616
rhardt@vedderprice.com
September 11, 2025
Via Edgar
Ms. Christina DiAngelo Fettig
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Driehaus Mutual Funds (File No. 811-07655) (the “Registrant”)
Dear Ms. Fettig:
On behalf of the Registrant, this letter is in response to the comments
you relayed during our telephone conference on August 27, 2025 regarding the Registrant’s Forms N-CSR and N-CEN for the period
ended December 31, 2024. Any changes made in response to these comments will be reflected in future filings.
Form N-CSR
1. Comment: With respect to the tailored shareholder reports, Form N-1A, Item 27A(d)(2), Instruction 8 requires
disclosures regarding a change in index from the one used for the preceding reporting period. For those Funds that had a benchmark change,
please explain supplementally the reason(s) for the changes, and for any future index changes, please include the required disclosures
in the tailored shareholder reports.
Response: As disclosed in the
Funds’ prospectus dated April 30, 2024, for those Funds that changed their index, they did so to show the returns of an index
that may be considered more broadly representative of the overall applicable securities market. Going forward the Registrant will include
the required disclosures regarding any index changes in the next tailored shareholder report.
2. Comment: With respect to the Schedule of Investments for Driehaus Event Driven Fund (page 35), please confirm that
the value for the Royal Caribbean Cruises holding is correct at $0.
Response: The Royal Caribbean
Cruises holding was called on August 13, 2024. The holding was previously part of a corporate bond basket of securities that was renewed
on November 1, 2024 and thus should not have been included as part of the Schedule of Investments as of December 31, 2024.
222
North LaSalle Street | Chicago, Illinois 60601 | T +1 312 609 7500 | F +1 312 609 5005
Vedder
Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in
California, Vedder Price Pte. Ltd., which operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.
Ms. Christina DiAngelo Fettig
September 11, 2025
Page 2
3. Comment: In the Securities Valuation section in the Notes to Financial Statements, please disclose how investments in
money market funds are valued.
Response: In the Registrant’s
Form N-CSR as of December 31, 2025, the Registrant will disclose that investments in money market funds are valued at the funds’
net asset value.
4. Comment: In the Significant Accounting Policies section in the Notes to Financial Statements, please disclose the method
used to allocate income and expenses and realized and unrealized capital gains and losses to each class of shares as required by FASB
ASC 946-235-50-2.
Response: In the Registrant’s
Form N-CSR as of December 31, 2025, the Registrant will provide such disclosure.
Form N-CEN
5. Comment: With respect to Item C.20.a (line of credit), please respond on a per Fund basis as required by the Form.
Response: The Registrant will
make this change going forward.
6. Comment: Please respond to Items C.20.b (interfund lending) and C.20.c (interfund borrowing).
Response: The Registrant will
include responses to these items going forward.
Form N-CSR/Website Disclosure
7. Comment: On the Registrant’s website, with respect to the information included at the link Annual Financial Statements
and Additional Information, the information responsive to Form N-CSR, Items 8, 9 and 11 differs from the text filed on Form N-CSR;
the disclosure should be accurate and consistent. In addition, although it was included in the Registrant’s Form N-CSR filing,
the information responsive to Form N-CSR, Item 10 is not included on the website. Also consider disclosing on the Registrant’s website
a parenthetical reference to the Form N-CSR item on the website; for example, Statement Regarding Basis for Approval of Investment
Advisory Contract (Form N-CSR, Item 11).
Response: In the Registrant’s
Form N-CSR as of December 31, 2025, the Registrant will make such disclosures consistent and include Item 10 on the website.
* * *
Ms. Christina DiAngelo Fettig
September 11, 2025
Page 3
If you have any questions regarding these responses, please call me at
(312) 609-7616.
Very truly yours,
/s/ Renee M. Hardt
Renee M. Hardt
Shareholder
RMH/ser
cc: Robert Kurinsky