SEC Company Response from HILLVIEW INVESTMENT TRUST II (CIK 0001111535) — Oct 4, 2005
HILLVIEW INVESTMENT TRUST II (CIK 0001111535)
Date: Oct. 4, 2005 · CIK: 0001111535 · Accession: 0001108086-05-000071
AI Filing Summary & Sentiment
File numbers found in text: 333-34806, 811-09901
Letter
October 4, 2005 VIA EDGAR TRANSMISSION Vincent DeStefano U. S. Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549
Re: Responses to SEC Comments on the Preliminary Proxy Materials of the Hillview Investment Trust II (SEC File Nos. 333-34806/811-09901
Dear Mr. DeStefano:
On September 20, 2005, Hillview Investment Trust II (the "Trust") filed preliminary proxy materials pursuant to paragraph (a) of Rule 20a-1 under the Investment Company Act of 1940, as amended (the "1940 Act") and pursuant to the requirements of Rule 14a-6(b) under the Securities Exchange Act of 1934. These proxy materials were filed in connection with a Special Meeting of Shareholders to be held on November 17, 2005 (the "Special Meeting"). The proxy materials will first be sent to shareholders on or about October 4, 2005.
The following letter responds to your comments to the preliminary proxy materials, as discussed in your telephone call on September 30, 2005 with Terrance James Reilly, Esq. of Greenberg Traurig, LLP. Your comments are in italics and the Trust's response follows below each comment.
1. In the section entitled "Comparison of the Hillview Fund and the World Fund," on the Comparative Fee Tables, you asked Mr. Reilly to confirm that the 1.23% listed under `Other Expenses' includes the 0.73% of short-sale dividends that are required to be treated as an expense.
We have been informed by the service provider for the World Funds that the `Other Expense' number of 1.23% does in fact include the 0.73% of short-sale dividends.
2. You requested that the Trust submit the "Tandy" representations.
A Tandy representation letter will be submitted to the SEC in connection with the definitive filing of the proxy materials.
Questions concerning this letter or the proxy materials may be directed to Terrance James Reilly at (215) 988-7815 or, in his absence, Steven M. Felsenstein at (215) 988-7837.
Very truly yours,
/s/ Joseph A. Bracken
Joseph A. Bracken
Treasurer
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HILLVIEW INVESTMENT TRUST II
700 The Times Building
Suburban Square
Ardmore, Pennsylvania 19003
(800) 660 - 9418
October 4, 2005
VIA EDGAR TRANSMISSION
Vincent DeStefano
U. S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Responses to SEC Comments on the Preliminary Proxy Materials of the
Hillview Investment Trust II (SEC File Nos. 333-34806/811-09901
Dear Mr. DeStefano:
On September 20, 2005, Hillview Investment Trust II (the "Trust") filed
preliminary proxy materials pursuant to paragraph (a) of Rule 20a-1 under the
Investment Company Act of 1940, as amended (the "1940 Act") and pursuant to the
requirements of Rule 14a-6(b) under the Securities Exchange Act of 1934. These
proxy materials were filed in connection with a Special Meeting of Shareholders
to be held on November 17, 2005 (the "Special Meeting"). The proxy materials
will first be sent to shareholders on or about October 4, 2005.
The following letter responds to your comments to the preliminary proxy
materials, as discussed in your telephone call on September 30, 2005 with
Terrance James Reilly, Esq. of Greenberg Traurig, LLP. Your comments are in
italics and the Trust's response follows below each comment.
1. In the section entitled "Comparison of the Hillview Fund and the World
Fund," on the Comparative Fee Tables, you asked Mr. Reilly to confirm that
the 1.23% listed under `Other Expenses' includes the 0.73% of short-sale
dividends that are required to be treated as an expense.
We have been informed by the service provider for the World Funds
that the `Other Expense' number of 1.23% does in fact include the
0.73% of short-sale dividends.
2. You requested that the Trust submit the "Tandy" representations.
A Tandy representation letter will be submitted to the SEC in
connection with the definitive filing of the proxy materials.
Questions concerning this letter or the proxy materials may be directed to
Terrance James Reilly at (215) 988-7815 or, in his absence, Steven M.
Felsenstein at (215) 988-7837.
Very truly yours,
/s/ Joseph A. Bracken
Joseph A. Bracken
Treasurer
cc: Nelson M. Burr
Arthur J. Brown
Marticha L. Cary
Laura A. Corsell
Steven M. Felsenstein
John Pasco, III
Terrance James Reilly
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