SEC Company Response from FAIRHOLME FUNDS INC (CIK 0001096344) — Mar 2, 2020
FAIRHOLME FUNDS INC (CIK 0001096344)
Date: March 2, 2020 · CIK: 0001096344 · Accession: 0000919574-20-002095
AI Filing Summary & Sentiment
File numbers found in text: 333-88517, 811-09607
Referenced dates: November 30, 2019
Letter
VIA EDGAR TRANSMISSION United States Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, DC 20549 Re: Fairholme Funds, Inc. (the “Company”) File Nos.: 333-88517 and 811-09607
Dear Mr. Eskildsen:
This letter responds, on behalf of the Company, to the staff’s comment of February 28, 2020 with respect to the staff’s review of the Company’s Annual Report, dated November 30, 2019. For your convenience, the comment is set forth below in italics and is followed immediately by the Company’s response.
Comment: In future reports to shareholders, in the Fairholme Fund’s Statement of Operations, state separately the amount of the net increase or decrease during the period in the unrealized appreciation or depreciation in the value of (1) investment securities of unaffiliated issuers and (2) investment securities of affiliated issuers. See Rule 6-07(7) of Regulation S-X.
Response: In future reports to shareholders, in its Statement of Operations the Fairholme Fund will state separately the amount of the net increase or decrease during the period in the unrealized appreciation or depreciation in the value of (1) investment securities of unaffiliated issuers and (2) investment securities of affiliated issuers, in accordance with Rule 6-07(7) of Regulation S-X.
* * * * * * * *
If you have any questions, please do not hesitate to contact the undersigned at (202) 737-8833.
Sincerely,
/s/ Joseph J. Nardello
Show Raw Text
CORRESP
1
filename1.htm
Seward
& Kissel LLP
901 K
Street NW
Suite
800
Washington,
DC 20001
March 2, 2020
VIA EDGAR TRANSMISSION
Chad D. Eskildsen
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
Re:
Fairholme Funds, Inc. (the “Company”)
File Nos.: 333-88517 and 811-09607
Dear Mr. Eskildsen:
This letter responds, on behalf of the Company, to
the staff’s comment of February 28, 2020 with respect to the staff’s review of the Company’s Annual Report, dated
November 30, 2019. For your convenience, the comment is set forth below in italics and is followed immediately by the Company’s
response.
Comment: In future reports to shareholders,
in the Fairholme Fund’s Statement of Operations, state separately the amount of the net increase or decrease during the period
in the unrealized appreciation or depreciation in the value of (1) investment securities of unaffiliated issuers and (2) investment
securities of affiliated issuers. See Rule 6-07(7) of Regulation S-X.
Response: In future reports to shareholders,
in its Statement of Operations the Fairholme Fund will state separately the amount of the net increase or decrease during the period
in the unrealized appreciation or depreciation in the value of (1) investment securities of unaffiliated issuers and (2) investment
securities of affiliated issuers, in accordance with Rule 6-07(7) of Regulation S-X.
* * * * * * * *
If you have any questions, please
do not hesitate to contact the undersigned at (202) 737-8833.
Sincerely,
/s/ Joseph J. Nardello
Joseph J. Nardello
cc:
Wayne Kellner, Treasurer
Erica Kapahi, Chief Compliance Officer
Paul M. Miller, Seward & Kissel LLP