Correspondence 0001580642-25-003205 from RENAISSANCE CAPITAL GREENWICH FUNDS (CIK 0001026634)
RENAISSANCE CAPITAL GREENWICH FUNDS (CIK 0001026634)
Date: May 21, 2025 · CIK: 0001026634 · Accession: 0001580642-25-003205
AI Filing Summary & Sentiment
File numbers found in text: 811-08049
Letter
Division of Investment Management US Securities and Exchange Commission SEC File No. 811-08049
RE: Renaissance Capital Greenwich Funds (the “Funds”)
Dear Ms. DiAngelo Fettig,
On behalf of the above-referenced Registrant, below are responses to Staff comments received orally on April 21, 2025.
Comment 1: Due to the unitary fee, confirm if the Adviser is current with payments to Fund service providers.
Response 1: The Registrant confirms that Renaissance Capital LLC, the Funds’ investment adviser (“the Adviser”) is current on payment of Fund service provider expenses for which invoices have been received.
Comment 2: NPORT item C6 identifies CVC Capital Partners as a restricted security. Explain whether any restricted security disclosure requirements under Regulation S-X Rule 12-12 were required in the Schedule of Investments.
Response 2: CVC Capital Partners was incorrectly flagged as restricted on the NPORT filings. The Registrant will correct this in future NPORT filings.
Comment 3: Confirm compliance with IRS diversification requirements.
Response 3: The Registrant confirms that the Funds are in compliance with IRS diversification requirements.
Comment 4: In future filings, disclose the valuation policy for investments in money market funds.
Response 4: The Registrant will make the requested change in future filings.
Comment 5A: Disclose whether acquired fund fees and expenses are excluded from the unitary fee.
Response 5A: Acquired fund fees and expenses are excluded from the unitary fee.
Comment 5B: It is noted that the Funds also bear asset-based custodial fees not covered under the Supervision and Administration Agreement. Is this an accurate disclosure? Were there not any custodial fees during the year?
Response 5B: The Registrant believes this was an inaccurate disclosure and will remove from future filings. There were asset-based custodial fees during the year, paid by the Adviser.
Comment 6: Did the Funds generate any acquired fund fees and expenses that would require disclosure in the fee table?
Response 6: The Funds did not generate any acquired fund fees and expenses that would require disclosure in the fee table.
Comment 7: On page 19 of the Financial Statements, titled ‘Other Information’, the Item 10 disclosure differs from the actual Item 10 disclosure in the N-CSR. Explain why they are different.
Response 7: The difference in the Item 10 disclosure was due to an inadvertent error in Item 10 of the N-CSR. In future N-CSR filings, Item 10 will reference the Financial Statements filed under N-CSR Item 7(a).
Comment 8: The parenthetical reference to the Registrant’s second fiscal half year is not required. It should be removed in future filings.
Response 8: The Registrant will make the requested change in future filings.
Comment 9: William Smith is signing Form N-CSR as President and Treasurer. The Registrant should also indicate that he is Principal Executive Officer and Principal Financial Officer
Response 9: The Registrant will make the requested change in future filings.
Comment 10: Should the box be checked on N-CEN Item C.3.b?
Response 10: The Registrant will check the box on Item C.3.b in future filings.
Please contact me at (203) 622-2978 if you have any additional questions or concerns.
Sincerely,
Karen Strube
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CORRESP 1 filename1.htm May 21, 2025 Christina DiAngelo Fettig Senior Staff Accountant Division of Investment Management US Securities and Exchange Commission RE: Renaissance Capital Greenwich Funds (the “Funds”) SEC File No. 811-08049 Dear Ms. DiAngelo Fettig, On behalf of the above-referenced Registrant, below are responses to Staff comments received orally on April 21, 2025. Comment 1: Due to the unitary fee, confirm if the Adviser is current with payments to Fund service providers. Response 1: The Registrant confirms that Renaissance Capital LLC, the Funds’ investment adviser (“the Adviser”) is current on payment of Fund service provider expenses for which invoices have been received. Comment 2: NPORT item C6 identifies CVC Capital Partners as a restricted security. Explain whether any restricted security disclosure requirements under Regulation S-X Rule 12-12 were required in the Schedule of Investments. Response 2: CVC Capital Partners was incorrectly flagged as restricted on the NPORT filings. The Registrant will correct this in future NPORT filings. Comment 3: Confirm compliance with IRS diversification requirements. Response 3: The Registrant confirms that the Funds are in compliance with IRS diversification requirements. Comment 4: In future filings, disclose the valuation policy for investments in money market funds. Response 4: The Registrant will make the requested change in future filings. Comment 5A: Disclose whether acquired fund fees and expenses are excluded from the unitary fee. Response 5A: Acquired fund fees and expenses are excluded from the unitary fee. Comment 5B: It is noted that the Funds also bear asset-based custodial fees not covered under the Supervision and Administration Agreement. Is this an accurate disclosure? Were there not any custodial fees during the year? Response 5B: The Registrant believes this was an inaccurate disclosure and will remove from future filings. There were asset-based custodial fees during the year, paid by the Adviser. Comment 6: Did the Funds generate any acquired fund fees and expenses that would require disclosure in the fee table? Response 6: The Funds did not generate any acquired fund fees and expenses that would require disclosure in the fee table. Comment 7: On page 19 of the Financial Statements, titled ‘Other Information’, the Item 10 disclosure differs from the actual Item 10 disclosure in the N-CSR. Explain why they are different. Response 7: The difference in the Item 10 disclosure was due to an inadvertent error in Item 10 of the N-CSR. In future N-CSR filings, Item 10 will reference the Financial Statements filed under N-CSR Item 7(a). Comment 8: The parenthetical reference to the Registrant’s second fiscal half year is not required. It should be removed in future filings. Response 8: The Registrant will make the requested change in future filings. Comment 9: William Smith is signing Form N-CSR as President and Treasurer. The Registrant should also indicate that he is Principal Executive Officer and Principal Financial Officer Response 9: The Registrant will make the requested change in future filings. Comment 10: Should the box be checked on N-CEN Item C.3.b? Response 10: The Registrant will check the box on Item C.3.b in future filings. Please contact me at (203) 622-2978 if you have any additional questions or concerns. Sincerely, Karen Strube Chief Compliance Officer