SEC Company Response from T. Rowe Price Institutional Income Funds, Inc. (CIK 0001169187) — Nov 29, 2004
T. Rowe Price Institutional Income Funds, Inc. (CIK 0001169187)
Date: Nov. 29, 2004 · CIK: 0001169187 · Accession: 0001169187-04-000012
AI Filing Summary & Sentiment
File numbers found in text: 333-84634, 811-21055
Letter
seccommentsonicp2.htm November 29, 2004 Keith O`Connell, Esquire Securities & Exchange Commission Division of Investment Management 450 Fifth Street, N.W. Washington, D.C. 20549
Re: T. Rowe Price Institutional Income Funds, Inc. ("Registrant") consisting of the following series: T. Rowe Price Institutional Core Plus Fund File Nos.: 333-84634/811-21055
Dear Mr. O`Connell:
Below are our responses to your November 24, 2004 oral comments on Pre-Effective Amendment No. 3 for the T. Rowe Price Institutional Income Funds, Inc. which was filed on September 16, 2004.
Comment #1:
The last sentence of the bullet on page 3 of the prospectus reads, "When shares are sold, money may be lost." This sentence should be revised as follows: Loss of money is a risk of investing in the fund.
Response:
The last sentence of the bullet on page 3 of the prospectus has been revised to read, "Loss of money is a risk of investing in the fund." We will make this change in all T. Rowe Price prospectuses.
Comment #2:
Under the subheading, "Rights Reserved by the Funds", please explain why it is appropriate for for the fund to have the right to cancel or rescind any purchase or exchange order upon notice to the shareholder within five business days of the trade, as written in item 4. The staff considers this subparagraph to be inconsistent with Rule 22(c)(1).
Response:
We have removed this item from "Rights Reserved by the Funds." We continue to believe the fund has a legal right to cancel or rescind orders under certain conditions and will address this comment in more detail in a separate memo to the staff.
Comment #3:
Under the subheading, "Rights Reserved by the Funds", item 8 states that the T. Rowe Price funds and their agents reserve the right to waive any redemption, small account, maintenance, or other fees charged to a group of shareholders. The right to waive redemption fees must be disclosed with greater specificity and the right to waive "other fees" is too open ended.
Response:
We have revised item 7 (originally item 8) to state that the T. Rowe price funds and their agents reserve the right to waive any wire, small account, maintenance, or fiduciary fees charged to any group of shareholders.
Very truly yours,
/s/Tawanda Cottman
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CORRESP
1
seccommentsonicp2.htm
November 29, 2004
Keith O`Connell, Esquire
Securities & Exchange Commission
Division of Investment Management
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: T. Rowe Price Institutional Income Funds, Inc. ("Registrant")
consisting of the following series:
T. Rowe Price Institutional Core Plus Fund
File Nos.: 333-84634/811-21055
Dear Mr. O`Connell:
Below are our responses to your November 24, 2004 oral comments on Pre-Effective Amendment No. 3 for the T. Rowe Price Institutional Income Funds, Inc. which was filed on September 16, 2004.
Comment #1:
The last sentence of the bullet on page 3 of the prospectus reads, "When shares are sold, money may be lost." This sentence should be revised as follows: Loss of money is a risk of investing in the fund.
Response:
The last sentence of the bullet on page 3 of the prospectus has been revised to read, "Loss of money is a risk of investing in the fund." We will make this change in all T. Rowe Price
prospectuses.
Comment #2:
Under the subheading, "Rights Reserved by the Funds", please explain why it is appropriate for for the fund to have the right to cancel or rescind any purchase or exchange order upon notice to the shareholder within five business days of the trade, as written in item 4. The staff considers this subparagraph to be inconsistent with Rule 22(c)(1).
Response:
We have removed this item from "Rights Reserved by the Funds." We continue to believe the fund has a legal right to cancel or rescind orders under certain conditions and will address this comment in more detail in a separate memo to the staff.
Comment #3:
Under the subheading, "Rights Reserved by the Funds", item 8 states that the T. Rowe Price funds and their agents reserve the right to waive any redemption, small account, maintenance, or other fees charged to a group of shareholders. The right to waive redemption fees must be disclosed with greater specificity and the right to waive "other fees" is too open ended.
Response:
We have revised item 7 (originally item 8) to state that the T. Rowe price funds and their agents reserve the right to waive any wire, small account, maintenance, or fiduciary fees charged to any group of shareholders.
Very truly yours,
/s/Tawanda Cottman
Tawanda Cottman
In connection with responding to your comments, T. Rowe Price acknowledges 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 proceedings initiated by the Commission or any person under the federal securities laws of the United States.
/s/Henry H. Hopkins
_______________________________
Henry H. Hopkins
Vice President
T. Rowe Price Institutional Income Funds, Inc.