SEC Company Response from MUNDER SERIES TRUST (CIK 0001214511) — Oct 19, 2005
MUNDER SERIES TRUST (CIK 0001214511)
Date: Oct. 19, 2005 · CIK: 0001214511 · Accession: 0001193125-05-204063
AI Filing Summary & Sentiment
File numbers found in text: 333-102943, 811-21294
Letter
Via EDGAR Correspondence Division of Investment Management Securities and Exchange Commission Washington, D.C. 20549 Re: Munder Series Trust (the “Registrant”), SEC File No. 333-102943, 811-21294: Post-Effective Amendment No. 12 to the Registrant’s Registration Statement on Form N-1A (the “Amendment”)
Dear Mr. Sandoe:
This letter responds to comments you provided to the undersigned of State Street Bank and Trust Company (“State Street”), the Registrant’s sub-administrator, in a telephonic discussion on Monday, October 17, 2005, with respect to the Amendment. The Amendment was filed on September 1, 2005, and included a Prospectus with respect to each series of the Registrant and a combined Statement of Additional Information. Summaries of the comments with respect to the Amendment, and the Registrant’s responses thereto, are provided below. All page references refer to the pages in the Amendment. Capitalized terms not defined herein should be given the meaning provided in the Amendment.
Prospectus – Balanced Fund
1. Global Comment1: On page 1 under the section “Goal”, disclosure should be provided in this Fund’s prospectus (and all prospectuses describing other series of the Registrant) with respect to whether or not the goal is a fundamental policy.
Response: The last sentence of the paragraph above such section states that “[u]nless this prospectus expressly provides otherwise, each goal, strategy and policy of the Fund may be changed by action of the Board of Trustees without shareholder approval.”
2. Comment: On page 1 under the section “Principal Investment Strategies”, please describe the market cap strategy of the Fund.
As discussed, to the extent a comment provided on a particular prospectus applies to the prospectus of another series of the Registrant included in the Amendment, disclosure has been revised in such prospectus(es) in accordance with the comment response provided (such comments are labeled “Global”).
Response: The paragraph under the section “Principal Investment Strategies” that begins “Equity securities are chosen…” has been revised to read as follows: The Fund’s equity allocation is further divided into multiple investment styles selected by the advisor, with each style managed independently of one another. Each equity style may represent one or more market capitalization ranges.”
“Equity securities are chosen in a manner consistent with the investment style represented. All of the equity styles focus on financial stability, quality of management and the fundamentals of a company. Growth styles tend to seek companies with above-average and sustainable earnings growth, while value styles tend to seek companies with lower price-to-earnings ratios.”
3. Global Comment: On page 1 in the fourth paragraph under the section “Principal Investment Strategies,” the disclosure states that the Fund’s equity securities may include common stocks (including shareholder of equity real estate investment trusts). Please include real estate risk as a risk factor.
Response: All of the Munder Equity Funds may invest in REITs, however, except with respect to the Real Estate Equity Investment Fund, investment in REITs is not a principal investment strategy. Rather, any investment in a REIT is an incidental result of adherence to the Fund’s principal investment strategy of seeking companies that meet the investment criteria otherwise described in the Prospectuses.
4. Global Comment: On page 22 in the third paragraph under “Distribution and Service Fees” please add, at the end of such paragraph, that such fees may cost an investor more than paying other types of sales charges.
Response: The disclosure has been revised to state “Because the fees are paid out of the Fund’s assets on an ongoing basis, over time these fees will increase the cost of an investment in Class A, Class B, Class C, Class K and Class R shares of the Fund, and may cost you more than paying other types of sales charges.”
5. Global Comment: On page 22 in the first sentence of the fourth paragraph under “Valuing Fund Shares”, the disclosure states that the fair valuation procedures contemplate that “…the advisor will establish a pricing committee…” Please revise the disclosure so that it is clear whether or not such a pricing committee has been established.
Response: The disclosure has been revised to state “[i]n accordance with procedures established by the Board of Trustees to fair value the Fund’s securities, the advisor has established a pricing committee to serve as its formal oversight body for the valuation of the Fund’s securities.”
6. Global Comment: On page 22 in the second sentence of the seventh paragraph under “Valuing Fund Shares”, the disclosure states that “[i]f the advisor believes that such events materially affect the value of portfolio securities, these securities may be valued at their fair market value…” Please change “may be valued at fair market value” to “will be valued at fair market value.”
Response: The disclosure has been revised as requested.
7. Comment: On page 25 in second paragraph under the “Portfolio Management Team,” the disclosure states that Mr. Kenny and Mr. Gura co-manage the multi-cap growth and large-cap growth segments of the Fund and share responsibility for investment decisions for the multi-cap growth segment of the Fund. Please clarify which person has primary responsibility for decision-making.
Response: The disclosure has been revised to state: Mr. Kenny and Mr. Gura co-manage the large-cap growth segment of the Fund, jointly making investment decisions within that segment. Mr. Gura is also responsible for managing the Fund’s multi-cap growth segment.
8. Comment: On page 26 in the disclosure with respect to Mr. Thomas Kenny under “Portfolio Management Team,” please clarify Mr. Kenny’s responsibilities at MCM from 1995 to 2005.
Response: The disclosure has been revised to state: Thomas P. Kenny, CFA, Director, Investment Management Services, has been a member of the Fund’s portfolio management team since 2005. Since joining MCM in 1995, Mr. Kenny has been a member of MCM’s large-cap growth investment discipline, and has worked with MCM’s technology research staff to select stocks appropriate for MCM’s large-capitalization core growth investment discipline. He leads MCM’s Public Fund and Taft-Hartley Investment Services Groups and manages equity and balanced portfolios for institutional clients.
9. Global Comment: On page S-1 in the second paragraph under the section, “Who May Purchase Shares – Class K Shares,” the disclosure states that “The Funds may refuse any purchase orders from ineligible investors who select Class K shares. Alternatively, ineligible investors may be issued Class A shares.” The investment in Class A shares is viewed by the SEC staff as a separate investment decision from an investment in Class K shares. Accordingly, an investor should not automatically receive Class A shares upon rejection from Class K shares and the disclosure should be revised accordingly.
Response: The disclosure has been revised to state: “The Funds may refuse any purchase orders from ineligible investors who select Class K shares.” Similar changes will be made in the applicable sections for Class R shares and Class Y shares.
10. Global Comment: On page S-13 in the second full paragraph under the section, “Frequent Purchases and Redemptions of Fund Shares and Short-Term Trading Fee,” the first sentence states “…if you redeem or exchange shares of the Equity Funds or the International Bond Fund…” Please include a separate reference for the Balanced Fund.
Response: The disclosure has been revised to state: “…if you redeem or exchange shares of the Balanced Fund, the Equity Funds or the International Bond Fund…”
11. Global Comment: On the back cover, the first sentence states “…the Shareholder Guide, which may be provided separately…” The Shareholder Guide provides information that is required by Form N-1A that is not otherwise disclosed in the prospectus and should therefore be provided with the prospectus. Please clarify.
Response: The first sentence has been revised to state: “Information relating to purchases and sales of shares of the Fund is provided in the Shareholder Guide, which is incorporated by reference into (and is considered a part of) this prospectus.”
Prospectus – Bond Fund
1. Comment: On page 1 under the section “Principal Investment Strategies”, please describe the credit quality strategy of the Fund.
Response: The disclosure in the last paragraph of such section states that “[t]he Fund primarily purchases bonds that are rated investment grade or better or, if unrated, are of comparable quality.” A detailed description of the various investment ratings is found on p. 10 of the Fund’s prospectus.
Prospectus – Cash Investment Fund
1. Global Comment: On page S-12 under the Section “Frequent Purchases and Redemption of Fund Shares,” tailor the disclosure, as applicable, with respect to the particular risks and other aspects of short-term trading that apply to the Fund as opposed to the current disclosure that speaks broadly to “The Munder Funds” and includes risks and other disclosure that is generally not relevant to a money market fund.
Response: The Shareholder Guide is a universal document that is included in every Prospectus. In an effort to achieve uniformity of disclosure across Prospectuses and to gain certain cost efficiencies, the Shareholder Guide does not vary from Prospectus to Prospectus. In addition, the Munder Funds’ policies on frequent trading as a whole are relevant to Money Market Fund investors who are most likely to be exchanging their shares for shares of longer-term Funds. Accordingly, no changes have been made.
Prospectus – International Bond Fund
1. Comment: On page 1 under the section “Principal Investment Strategies”, the disclosure in the third paragraph states that the Fund will invest at least 80% of its assets in “securities of issuers in at least three foreign countries.” Please confirm in your comment response letter the percent of assets of the Fund invested outside of the United States and the number of foreign countries the Fund invests in. See footnote 42 to Release No. IC-24828, Investment Company Names.
Response: As disclosed in the audited financial statements of the Fund, as of June 30, 2005, 91.5% of the Fund’s net assets was invested in foreign bonds and notes of 18 foreign countries and the European Investment Bank.
2. Comment: On pages 22-23 in the disclosure with respect to Mr. Paul M. LaCoursiere under “Portfolio Management Team,” please clarify Mr. LaCoursiere’s occupational history prior to 2002.
Response: The disclosure has been revised to state: “Paul M. LaCoursiere, Portfolio Manager, has been a member of the Fund’s portfolio management team since 2004. Since joining MCM in 2002, Mr. LaCoursiere has managed fixed income portfolios, provided quantitative investment strategy analysis, and specialized in trading government and mortgage-backed bonds. He is also a member of MCM’s Taft-Hartley and Insurance teams. Before joining MCM, Mr. LaCoursiere was a full-time student in the University of Chicago Graduate School of Business. From 2000 to 2001, he worked for International Truck and Engine Company in its Corporate Finance Department.”
Prospectus – International Equity Fund
1. Comment: On page 1 under the section “Principal Investment Strategies”, the disclosure in the third paragraph states that the Fund will invest at least 80% of its assets in “securities of issuers in at least three foreign countries.” Please confirm in your comment response letter the percent of assets of the Fund invested outside of the United States and the number of foreign countries the Fund invests in. See footnote 42 to Release No. IC-24828, Investment Company Names.
Response: As disclosed in the Fund’s audited financial statements, as of June 30, 2005, 93.2% of the Fund’s net assets was invested in the common stocks of 30 foreign countries.
Please be advised that the disclosure after the first two paragraphs under the heading “Principal Investment Strategies” has been revised in its entirety to state: “The advisor employs a highly quantitative approach to investing. Stocks are selected based on fundamental factors that the advisor believes are effective predictors of stock performance. In an effort to manage the volatility of the Fund’s performance, country and sector weightings are targeted to remain within specific ranges as compared to the Morgan Stanley Capital International Europe, Australasia, Far East (MSCI EAFE) Index.”
“Utilizing a variety of quantitative analyses, the advisor seeks to identify foreign stocks that offer favorable risk-adjusted returns over time. Securities in which the Fund invests will primarily be from countries represented in the MSCI EAFE Index universe, but may also include larger capitalization companies in other countries.”
“The Fund may also engage in foreign currency transactions, and may utilize exchange-traded funds to manage liquidity.”
2. Comment: On page 22 in second paragraph under the “Portfolio Management Team,” please clarify the roles of Messrs. Kozeliski and Lacayo in managing the Fund. For instance, the disclosure states that Mr. Kozeliski is a co-manager, but that Mr. Lacayo is only a member of the team and not the other co-manager.
Response: The disclosure under the heading “Portfolio Management Team” has been revised in its entirety to state: “A team of professionals employed by MCM makes investment decisions for the Fund.”
“The team consists of T. Scott Wittman, Brian E. Kozeliski and Armando J. Lacayo. Mr. Wittman is responsible for the development of the quantitative model utilized in managing the Fund. In addition, together with Mr. Kozeliski, Mr. Wittman is responsible for day-to-day management of the Fund. Mr. Wittman has final investment authority for the Fund. Mr. Lacayo is responsible for providing quantitative research utilized in making investment decisions for the Fund.”
“Brian E. Kozeliski, CFA, Portfolio Manager, has been a member of the Fund’s portfolio management team since 2000. From 2000 through 2005, Mr. Kozeliski’s role was as a member of MCM’s World Asset Management division (a division of MCM focused on indexed and quantitative investing), providing analytical and trading support for World Asset Management’s complete international equity product line. In March 2005, Mr. Kozeliski joined MCM’s actively-managed international equity team, where he assumed day-to-day portfolio management responsibility for the Fund.”
“Armando J. Lacayo, Director, Quantitative Research, and Portfolio Manager, has been a member of the Fund’s portfolio management team since 2005. Mr. Lacayo provides quantitative research, including attribution analysis, for all of MCM’s equity investment
styles and manages MCM’s quantitative support group. Prior to joining MCM in 2000, Mr. Lacayo worked at Barra Inc. as a consultant, assisting equity clients develop risk management solutions, and at Lehman Brothers as a research analyst.”
“T. Scott Wittman, CFA, Director, International Investments, has been a member of the Fund’s portfolio management team since joining MCM in 2005. Prior to joining MCM, Mr. Wittman was a self-employed Financial Consultant from 2000 to 2005, during which time he provided strategic analysis and planning, conducted operational effectiveness studies, enhanced risk management, and investment modeling, for various investment managers. Mr. Wittman was also previously employed by Vantage Investment Advisors from 1991 through 2000, where he began as a Senior Vice Presi
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CORRESP 1 filename1.htm Munder Series Trust State Street Bank and Trust Company 225 Franklin Street, 2nd Floor Boston, MA 02110 Via EDGAR Correspondence October 19, 2005 Christian Sandoe Division of Investment Management Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re: Munder Series Trust (the “Registrant”), SEC File No. 333-102943, 811-21294: Post-Effective Amendment No. 12 to the Registrant’s Registration Statement on Form N-1A (the “Amendment”) Dear Mr. Sandoe: This letter responds to comments you provided to the undersigned of State Street Bank and Trust Company (“State Street”), the Registrant’s sub-administrator, in a telephonic discussion on Monday, October 17, 2005, with respect to the Amendment. The Amendment was filed on September 1, 2005, and included a Prospectus with respect to each series of the Registrant and a combined Statement of Additional Information. Summaries of the comments with respect to the Amendment, and the Registrant’s responses thereto, are provided below. All page references refer to the pages in the Amendment. Capitalized terms not defined herein should be given the meaning provided in the Amendment. Prospectus – Balanced Fund 1. Global Comment1: On page 1 under the section “Goal”, disclosure should be provided in this Fund’s prospectus (and all prospectuses describing other series of the Registrant) with respect to whether or not the goal is a fundamental policy. Response: The last sentence of the paragraph above such section states that “[u]nless this prospectus expressly provides otherwise, each goal, strategy and policy of the Fund may be changed by action of the Board of Trustees without shareholder approval.” 2. Comment: On page 1 under the section “Principal Investment Strategies”, please describe the market cap strategy of the Fund. 1 As discussed, to the extent a comment provided on a particular prospectus applies to the prospectus of another series of the Registrant included in the Amendment, disclosure has been revised in such prospectus(es) in accordance with the comment response provided (such comments are labeled “Global”). Response: The paragraph under the section “Principal Investment Strategies” that begins “Equity securities are chosen…” has been revised to read as follows: The Fund’s equity allocation is further divided into multiple investment styles selected by the advisor, with each style managed independently of one another. Each equity style may represent one or more market capitalization ranges.” “Equity securities are chosen in a manner consistent with the investment style represented. All of the equity styles focus on financial stability, quality of management and the fundamentals of a company. Growth styles tend to seek companies with above-average and sustainable earnings growth, while value styles tend to seek companies with lower price-to-earnings ratios.” 3. Global Comment: On page 1 in the fourth paragraph under the section “Principal Investment Strategies,” the disclosure states that the Fund’s equity securities may include common stocks (including shareholder of equity real estate investment trusts). Please include real estate risk as a risk factor. Response: All of the Munder Equity Funds may invest in REITs, however, except with respect to the Real Estate Equity Investment Fund, investment in REITs is not a principal investment strategy. Rather, any investment in a REIT is an incidental result of adherence to the Fund’s principal investment strategy of seeking companies that meet the investment criteria otherwise described in the Prospectuses. 4. Global Comment: On page 22 in the third paragraph under “Distribution and Service Fees” please add, at the end of such paragraph, that such fees may cost an investor more than paying other types of sales charges. Response: The disclosure has been revised to state “Because the fees are paid out of the Fund’s assets on an ongoing basis, over time these fees will increase the cost of an investment in Class A, Class B, Class C, Class K and Class R shares of the Fund, and may cost you more than paying other types of sales charges.” 5. Global Comment: On page 22 in the first sentence of the fourth paragraph under “Valuing Fund Shares”, the disclosure states that the fair valuation procedures contemplate that “…the advisor will establish a pricing committee…” Please revise the disclosure so that it is clear whether or not such a pricing committee has been established. Response: The disclosure has been revised to state “[i]n accordance with procedures established by the Board of Trustees to fair value the Fund’s securities, the advisor has established a pricing committee to serve as its formal oversight body for the valuation of the Fund’s securities.” 6. Global Comment: On page 22 in the second sentence of the seventh paragraph under “Valuing Fund Shares”, the disclosure states that “[i]f the advisor believes that such events materially affect the value of portfolio securities, these securities may be valued at their fair market value…” Please change “may be valued at fair market value” to “will be valued at fair market value.” Response: The disclosure has been revised as requested. 7. Comment: On page 25 in second paragraph under the “Portfolio Management Team,” the disclosure states that Mr. Kenny and Mr. Gura co-manage the multi-cap growth and large-cap growth segments of the Fund and share responsibility for investment decisions for the multi-cap growth segment of the Fund. Please clarify which person has primary responsibility for decision-making. 2 Response: The disclosure has been revised to state: Mr. Kenny and Mr. Gura co-manage the large-cap growth segment of the Fund, jointly making investment decisions within that segment. Mr. Gura is also responsible for managing the Fund’s multi-cap growth segment. 8. Comment: On page 26 in the disclosure with respect to Mr. Thomas Kenny under “Portfolio Management Team,” please clarify Mr. Kenny’s responsibilities at MCM from 1995 to 2005. Response: The disclosure has been revised to state: Thomas P. Kenny, CFA, Director, Investment Management Services, has been a member of the Fund’s portfolio management team since 2005. Since joining MCM in 1995, Mr. Kenny has been a member of MCM’s large-cap growth investment discipline, and has worked with MCM’s technology research staff to select stocks appropriate for MCM’s large-capitalization core growth investment discipline. He leads MCM’s Public Fund and Taft-Hartley Investment Services Groups and manages equity and balanced portfolios for institutional clients. 9. Global Comment: On page S-1 in the second paragraph under the section, “Who May Purchase Shares – Class K Shares,” the disclosure states that “The Funds may refuse any purchase orders from ineligible investors who select Class K shares. Alternatively, ineligible investors may be issued Class A shares.” The investment in Class A shares is viewed by the SEC staff as a separate investment decision from an investment in Class K shares. Accordingly, an investor should not automatically receive Class A shares upon rejection from Class K shares and the disclosure should be revised accordingly. Response: The disclosure has been revised to state: “The Funds may refuse any purchase orders from ineligible investors who select Class K shares.” Similar changes will be made in the applicable sections for Class R shares and Class Y shares. 10. Global Comment: On page S-13 in the second full paragraph under the section, “Frequent Purchases and Redemptions of Fund Shares and Short-Term Trading Fee,” the first sentence states “…if you redeem or exchange shares of the Equity Funds or the International Bond Fund…” Please include a separate reference for the Balanced Fund. Response: The disclosure has been revised to state: “…if you redeem or exchange shares of the Balanced Fund, the Equity Funds or the International Bond Fund…” 11. Global Comment: On the back cover, the first sentence states “…the Shareholder Guide, which may be provided separately…” The Shareholder Guide provides information that is required by Form N-1A that is not otherwise disclosed in the prospectus and should therefore be provided with the prospectus. Please clarify. Response: The first sentence has been revised to state: “Information relating to purchases and sales of shares of the Fund is provided in the Shareholder Guide, which is incorporated by reference into (and is considered a part of) this prospectus.” Prospectus – Bond Fund 1. Comment: On page 1 under the section “Principal Investment Strategies”, please describe the credit quality strategy of the Fund. 3 Response: The disclosure in the last paragraph of such section states that “[t]he Fund primarily purchases bonds that are rated investment grade or better or, if unrated, are of comparable quality.” A detailed description of the various investment ratings is found on p. 10 of the Fund’s prospectus. Prospectus – Cash Investment Fund 1. Global Comment: On page S-12 under the Section “Frequent Purchases and Redemption of Fund Shares,” tailor the disclosure, as applicable, with respect to the particular risks and other aspects of short-term trading that apply to the Fund as opposed to the current disclosure that speaks broadly to “The Munder Funds” and includes risks and other disclosure that is generally not relevant to a money market fund. Response: The Shareholder Guide is a universal document that is included in every Prospectus. In an effort to achieve uniformity of disclosure across Prospectuses and to gain certain cost efficiencies, the Shareholder Guide does not vary from Prospectus to Prospectus. In addition, the Munder Funds’ policies on frequent trading as a whole are relevant to Money Market Fund investors who are most likely to be exchanging their shares for shares of longer-term Funds. Accordingly, no changes have been made. Prospectus – International Bond Fund 1. Comment: On page 1 under the section “Principal Investment Strategies”, the disclosure in the third paragraph states that the Fund will invest at least 80% of its assets in “securities of issuers in at least three foreign countries.” Please confirm in your comment response letter the percent of assets of the Fund invested outside of the United States and the number of foreign countries the Fund invests in. See footnote 42 to Release No. IC-24828, Investment Company Names. Response: As disclosed in the audited financial statements of the Fund, as of June 30, 2005, 91.5% of the Fund’s net assets was invested in foreign bonds and notes of 18 foreign countries and the European Investment Bank. 2. Comment: On pages 22-23 in the disclosure with respect to Mr. Paul M. LaCoursiere under “Portfolio Management Team,” please clarify Mr. LaCoursiere’s occupational history prior to 2002. Response: The disclosure has been revised to state: “Paul M. LaCoursiere, Portfolio Manager, has been a member of the Fund’s portfolio management team since 2004. Since joining MCM in 2002, Mr. LaCoursiere has managed fixed income portfolios, provided quantitative investment strategy analysis, and specialized in trading government and mortgage-backed bonds. He is also a member of MCM’s Taft-Hartley and Insurance teams. Before joining MCM, Mr. LaCoursiere was a full-time student in the University of Chicago Graduate School of Business. From 2000 to 2001, he worked for International Truck and Engine Company in its Corporate Finance Department.” Prospectus – International Equity Fund 1. Comment: On page 1 under the section “Principal Investment Strategies”, the disclosure in the third paragraph states that the Fund will invest at least 80% of its assets in “securities of issuers in at least three foreign countries.” Please confirm in your comment response letter the percent of assets of the Fund invested outside of the United States and the number of foreign countries the Fund invests in. See footnote 42 to Release No. IC-24828, Investment Company Names. 4 Response: As disclosed in the Fund’s audited financial statements, as of June 30, 2005, 93.2% of the Fund’s net assets was invested in the common stocks of 30 foreign countries. Please be advised that the disclosure after the first two paragraphs under the heading “Principal Investment Strategies” has been revised in its entirety to state: “The advisor employs a highly quantitative approach to investing. Stocks are selected based on fundamental factors that the advisor believes are effective predictors of stock performance. In an effort to manage the volatility of the Fund’s performance, country and sector weightings are targeted to remain within specific ranges as compared to the Morgan Stanley Capital International Europe, Australasia, Far East (MSCI EAFE) Index.” “Utilizing a variety of quantitative analyses, the advisor seeks to identify foreign stocks that offer favorable risk-adjusted returns over time. Securities in which the Fund invests will primarily be from countries represented in the MSCI EAFE Index universe, but may also include larger capitalization companies in other countries.” “The Fund may also engage in foreign currency transactions, and may utilize exchange-traded funds to manage liquidity.” 2. Comment: On page 22 in second paragraph under the “Portfolio Management Team,” please clarify the roles of Messrs. Kozeliski and Lacayo in managing the Fund. For instance, the disclosure states that Mr. Kozeliski is a co-manager, but that Mr. Lacayo is only a member of the team and not the other co-manager. Response: The disclosure under the heading “Portfolio Management Team” has been revised in its entirety to state: “A team of professionals employed by MCM makes investment decisions for the Fund.” “The team consists of T. Scott Wittman, Brian E. Kozeliski and Armando J. Lacayo. Mr. Wittman is responsible for the development of the quantitative model utilized in managing the Fund. In addition, together with Mr. Kozeliski, Mr. Wittman is responsible for day-to-day management of the Fund. Mr. Wittman has final investment authority for the Fund. Mr. Lacayo is responsible for providing quantitative research utilized in making investment decisions for the Fund.” “Brian E. Kozeliski, CFA, Portfolio Manager, has been a member of the Fund’s portfolio management team since 2000. From 2000 through 2005, Mr. Kozeliski’s role was as a member of MCM’s World Asset Management division (a division of MCM focused on indexed and quantitative investing), providing analytical and trading support for World Asset Management’s complete international equity product line. In March 2005, Mr. Kozeliski joined MCM’s actively-managed international equity team, where he assumed day-to-day portfolio management responsibility for the Fund.” “Armando J. Lacayo, Director, Quantitative Research, and Portfolio Manager, has been a member of the Fund’s portfolio management team since 2005. Mr. Lacayo provides quantitative research, including attribution analysis, for all of MCM’s equity investment 5 styles and manages MCM’s quantitative support group. Prior to joining MCM in 2000, Mr. Lacayo worked at Barra Inc. as a consultant, assisting equity clients develop risk management solutions, and at Lehman Brothers as a research analyst.” “T. Scott Wittman, CFA, Director, International Investments, has been a member of the Fund’s portfolio management team since joining MCM in 2005. Prior to joining MCM, Mr. Wittman was a self-employed Financial Consultant from 2000 to 2005, during which time he provided strategic analysis and planning, conducted operational effectiveness studies, enhanced risk management, and investment modeling, for various investment managers. Mr. Wittman was also previously employed by Vantage Investment Advisors from 1991 through 2000, where he began as a Senior Vice Presi