SEC Company Response from GuideStone Funds (CIK 0001131013) — Apr 25, 2022
GuideStone Funds (CIK 0001131013)
Date: April 25, 2022 · CIK: 0001131013 · Accession: 0001137439-22-000328
AI Filing Summary & Sentiment
File numbers found in text: 333-53432, 811-10263
Letter
VIA EDGAR Division of Investment Management Attention: Mr. Raymond Be, Esquire Re: GuideStone Funds File Nos. 333-53432, 811-10263
Dear Mr. Be:
On behalf of GuideStone Funds (the “Registrant”) below you will find the Registrant’s responses to the comments conveyed by you on April 12, 2022, with regard to Post-Effective Amendment No. 87 (the “Amendment”) to the Registrant’s registration statement on Form N-1A. The Amendment was filed with the U.S. Securities and Exchange Commission (the “SEC”) on February 25, 2022, pursuant to the Investment Company Act of 1940, as amended (the “1940 Act”), and Rule 485(a)(1) under the Securities Act of 1933, as amended (the “Securities Act”).
Below we have provided your comments and the Registrant’s response to each comment. These responses will be incorporated into a post-effective amendment filing to be made pursuant to Rule 485(b) of the Securities Act. Capitalized terms not otherwise defined in this letter have the meanings assigned to the terms in the Registration Statement.
U.S. Securities and Exchange Commission
Page 2
Prospectus
1) Comment: Please provide completed fee tables prior to effectiveness.
Response: The Registrant has included the completed fee tables as Exhibit A to this filing.
2) Comment: To the extent that China and variable interest entity (“VIE”) disclosures are described in a Fund’s principal investment risks section, also discuss these in the Fund’s principal investment strategies section.
Response: The requested disclosure has been added to the Emerging Markets Equity Fund’s principal investment strategies section. Please see Exhibit B. The Registrant has removed China and VIE disclosures from the Global Bond Fund and the International Equity Fund’s principal investment risks because these Funds’ investments in Chinese securities are at or below 3% of each Fund’s net assets, and the Registrant does not consider them principal investment strategies for the Funds.
In connection with the Registrant’s responses to the SEC Staff’s comments on the Registration Statement, as requested by the Staff, the Registrant acknowledges that the Registrant is responsible for the adequacy of the disclosure in the Registrant’s filings, notwithstanding any review, comments, action, or absence of action by the Staff.
Please do not hesitate to contact me at (202) 419-8416, or Jessica D. Burt at (202) 419-8409, if you have any questions or wish to discuss any of the responses presented above.
Respectfully submitted,
/s/ Cillian M. Lynch
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CORRESP
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filename1.htm
Stradley Ronon Stevens & Young, LLP
2000 K Street, N.W., Suite 700
Washington, D.C. 20006
Telephone 202-822-9611
Fax 202-822-0140
www.stradley.com
Cillian M. Lynch
(202) 419-8416
clynch@stradley.com
April 25, 2022
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549-9303
Attention:
Mr. Raymond Be, Esquire
Re:
GuideStone Funds
File Nos. 333-53432, 811-10263
Dear Mr. Be:
On behalf of GuideStone Funds (the “Registrant”) below you will find the Registrant’s responses to the comments conveyed by you on April 12, 2022, with regard to Post-Effective
Amendment No. 87 (the “Amendment”) to the Registrant’s registration statement on Form N-1A. The Amendment was filed with the U.S. Securities and Exchange Commission (the “SEC”) on February 25, 2022, pursuant to the Investment Company Act of 1940, as
amended (the “1940 Act”), and Rule 485(a)(1) under the Securities Act of 1933, as amended (the “Securities Act”).
Below we have provided your comments and the Registrant’s response to each comment. These responses will be incorporated into a post-effective amendment filing to be made pursuant
to Rule 485(b) of the Securities Act. Capitalized terms not otherwise defined in this letter have the meanings assigned to the terms in the Registration Statement.
U.S. Securities and Exchange Commission
Page 2
Prospectus
1) Comment: Please provide completed fee tables prior to effectiveness.
Response: The Registrant has included the completed fee tables as Exhibit A to this filing.
2) Comment: To the extent that China and variable interest entity (“VIE”) disclosures are described in a Fund’s principal investment risks section, also discuss these in the
Fund’s principal investment strategies section.
Response: The requested disclosure has been added to the Emerging Markets Equity Fund’s principal investment strategies section. Please see Exhibit B. The Registrant has removed China and VIE
disclosures from the Global Bond Fund and the International Equity Fund’s principal investment risks because these Funds’ investments in Chinese securities are at or below 3% of each Fund’s net assets, and the Registrant does not consider them
principal investment strategies for the Funds.
In connection with the Registrant’s responses to the SEC Staff’s comments on the Registration Statement, as requested by the Staff, the Registrant acknowledges that the Registrant is responsible for the
adequacy of the disclosure in the Registrant’s filings, notwithstanding any review, comments, action, or absence of action by the Staff.
Please do not hesitate to contact me at (202) 419-8416, or Jessica D. Burt at (202) 419-8409, if you have any questions or wish to discuss any of the responses presented
above.
Respectfully submitted,
/s/ Cillian M. Lynch
Cillian M. Lynch, Esquire
cc:
Melanie Childers
Matthew A. Wolfe, Esquire
Jessica D. Burt, Esquire
Exhibit A
Exhibit B