SEC Company Response from ARBITRAGE FUNDS (CIK 0001105076) — Sep 14, 2004
ARBITRAGE FUNDS (CIK 0001105076)
Date: Sept. 14, 2004 · CIK: 0001105076 · Accession: 0001111830-04-000290
AI Filing Summary & Sentiment
File numbers found in text: 333-30470, 811-09815
Letter
Re: The Arbitrage Funds (the "Fund") File Nos. 811-09815; 333-30470 Response to Commission's Comments on Form N-CSR for Fiscal Year Ended May 31, 2004
THE ARBITRAGE FUND
September 14, 2004
Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549
Ladies and Gentlemen:
Ms. Christina DiLino of the Commission's staff contacted us to provide comments on the Fund's Form N-CSR for the fiscal year ended May 31, 2004. The following are the comments provided and the Fund's response to each:
1. When quoting Fund performance in the Management Discussion of Fund Performance, specify the share class to which the returns relate.
RESPONSE: In future reports, quotations of Fund performance will specify the class to which the returns relate.
2. In the performance line graph, explain why the Fund's returns for each of the most recent four quarters are identical (4.36%).
RESPONSE: This was a typographical error in the EDGAR filing. However, the line graph that appears in the Annual Report is accurate.
3. In the Portfolio of Investments, escrowed rights should be reflected as "non-income producing" securities by a footnote.
RESPONSE: In future reports, a footnote will reflect that escrowed rights are "non-income producing."
4. In accordance with Regulation S-X, securities that are subject to open put or call contracts should be identified by a footnote.
RESPONSE: In future reports, securities that are subject to open put or call options will be identified by a footnote.
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5. The amounts of "ROSCOP" adjustments and adjustments resulting from book-to-tax differences should be disclosed in the Notes to Financial Statements.
RESPONSE: In future reports, the amounts of "ROSCOP" adjustments and adjustments resulting from book-to-tax differences will be disclosed in the Notes to Financial Statements.
6. When will the current Annual Report be posted to the Fund's Website?
RESPONSE: The current Annual Report was posted to the Fund's Website on August 26, 2004.
Thank you for your comments. Please contact the undersigned at 513/587-3402 if you have any questions or comments concerning this filing.
Very truly yours,
/s/ Mark J. Seger
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THE ARBITRAGE FUND
September 14, 2004
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: The Arbitrage Funds (the "Fund")
File Nos. 811-09815; 333-30470
Response to Commission's Comments on Form N-CSR for Fiscal Year
Ended May 31, 2004
Ladies and Gentlemen:
Ms. Christina DiLino of the Commission's staff contacted us to provide
comments on the Fund's Form N-CSR for the fiscal year ended May 31, 2004. The
following are the comments provided and the Fund's response to each:
1. When quoting Fund performance in the Management Discussion of Fund
Performance, specify the share class to which the returns relate.
RESPONSE: In future reports, quotations of Fund performance will specify the
class to which the returns relate.
2. In the performance line graph, explain why the Fund's returns for each
of the most recent four quarters are identical (4.36%).
RESPONSE: This was a typographical error in the EDGAR filing. However, the line
graph that appears in the Annual Report is accurate.
3. In the Portfolio of Investments, escrowed rights should be reflected as
"non-income producing" securities by a footnote.
RESPONSE: In future reports, a footnote will reflect that escrowed rights are
"non-income producing."
4. In accordance with Regulation S-X, securities that are subject to open
put or call contracts should be identified by a footnote.
RESPONSE: In future reports, securities that are subject to open put or call
options will be identified by a footnote.
<PAGE>
5. The amounts of "ROSCOP" adjustments and adjustments resulting from
book-to-tax differences should be disclosed in the Notes to Financial
Statements.
RESPONSE: In future reports, the amounts of "ROSCOP" adjustments and adjustments
resulting from book-to-tax differences will be disclosed in the Notes to
Financial Statements.
6. When will the current Annual Report be posted to the Fund's Website?
RESPONSE: The current Annual Report was posted to the Fund's Website on August
26, 2004.
Thank you for your comments. Please contact the undersigned at 513/587-3402
if you have any questions or comments concerning this filing.
Very truly yours,
/s/ Mark J. Seger
Mark J. Seger
Assistant Treasurer
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