SEC Comment Letter for VIKING MUTUAL FUNDS (CIK 0001082744) — Mar 17, 2005
VIKING MUTUAL FUNDS (CIK 0001082744)
Date: March 17, 2005 · CIK: 0001082744 · Accession: 0000000000-05-012621
AI Filing Summary & Sentiment
File numbers found in text: 811-9277
Letter
<DESCRIPTION>COMMENTS ON N-CSR
_____________________________________________ From: Rupert, Kevin C. Sent: Friday, March 04, 2005 4:21 PM To: `vikingfd@ndak.net` Subject: Viking Mutual Funds (811-9277)
Mr. Miller,
1. Attached is the adopting release. In addition, please read Item 22 to Form N-1A and comply with the requirements therein.
2. The item 22 disclosure seems to be missing in the N-CSR for Viking Mutual Funds.
3. Please respond by EDGAR correspondence.
4. Please revise and re-file the N-CSR, if required, complying with all Item 22 provisions. Re-mailing is also likely.
5. You must then complete new SOX certifications.
6. Your response should discuss how this error happened and how it will be corrected.
7. Discuss internal control with regard to accurate and timely filing of required information to the SEC and delivery of such information to shareholders.
8. Double check, and revise as needed, the disclosed sales loads and the inception points for the line graphs and also check the total returns per our discussion (e.g., Small-Cap Value Fund and others).
9. Discuss the responsibility for the cost of this corrective action.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. Since the fund and its management are in possession of all facts relating to a fund`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that
* the fund 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 * the fund 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.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Investment Management in our review of your filing or in response to our comments on your filing.
You may reach me at 202-551-6966.
Kevin Rupert
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>viking.txt
<DESCRIPTION>COMMENTS ON N-CSR
<TEXT>
_____________________________________________
From: Rupert, Kevin C.
Sent: Friday, March 04, 2005 4:21 PM
To: `vikingfd@ndak.net`
Subject: Viking Mutual Funds (811-9277)
Mr. Miller,
1. Attached is the adopting release. In addition, please read Item
22 to Form N-1A and comply with the requirements therein.
2. The item 22 disclosure seems to be missing in the N-CSR for
Viking Mutual Funds.
3. Please respond by EDGAR correspondence.
4. Please revise and re-file the N-CSR, if required, complying with
all Item 22 provisions. Re-mailing is also likely.
5. You must then complete new SOX certifications.
6. Your response should discuss how this error happened and how it
will be corrected.
7. Discuss internal control with regard to accurate and timely
filing of required information to the SEC and delivery of such
information to shareholders.
8. Double check, and revise as needed, the disclosed sales loads
and the inception points for the line graphs and also check the total
returns per our discussion (e.g., Small-Cap Value Fund and others).
9. Discuss the responsibility for the cost of this corrective
action.
We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require. Since the
fund and its management are in possession of all facts relating to a
fund`s disclosure, they are responsible for the accuracy and adequacy
of the disclosures they have made.
In connection with responding to our comments, please provide,
in writing, a statement from the company acknowledging that
* the fund 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
* the fund 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.
In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the
Division of Investment Management in our review of your filing or in
response to our comments on your filing.
You may reach me at 202-551-6966.
Kevin Rupert
</TEXT>
</DOCUMENT>