SEC Company Response from SYCUAN FUNDS (CIK 0001253771) — Feb 4, 2005
SYCUAN FUNDS (CIK 0001253771)
Date: Feb. 4, 2005 · CIK: 0001253771 · Accession: 0001162044-05-000028
AI Filing Summary & Sentiment
File numbers found in text: 333-107049, 811-21401
Letter
Office of Disclosure and Review Division of Investment Management United States Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 RE: Sycuan Funds (the "Trust"); File Nos. 811-21401 and 333-107049
Dear Ms. Delano:
Please find below Trust’s responses to oral comments from the staff received on January 5, 2005. For your convenience, I have summarized the staff’s comments.
1.
Comment: In future filings please include the Item 22(b)(6) under the Trustees Table in annual reports.
Response: The Trust will include Item 22(b)(6) in future annual reports.
2.
Comment: In future shareholder reports, please enhance the disclosure regarding fair valuation.
Response: The Trust’s Board of Trustees has adopted Good Faith Pricing Guidelines that discuss the factors considered when fair valuing investments. Some of these factors will be disclosed in the Notes to Financial Statements in future shareholder reports to enhance the disclosure.
3.
Comment: Why does footnote *** say “based on average daily net assets” in the 2004 annual report.
Response: The footnote was inadvertently added to the annual report, and will be removed from future reports.
4.
Other Comments: The staff requested that the Trust provide a statement in response to the generic “Tandy” letter.
Response: The Trust hereby acknowledges that the fund is responsible for the adequacy and accuracy of the disclosure in the filings reviewed by the staff; 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 Trust may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
__________________________________
If you have any questions or additional comments, please call the undersigned at 619-444-4043.
Respectfully,
/s/ Jeff Provence
Show Raw Text
CORRESP 1 sycuancorr.htm Sycuan Sycuan Funds 3007 Dehesa Road, El Cajon, California 92019 Phone (619) 444-4043 Fax (619) 444-4775 February 4, 2005 Christina Delano Office of Disclosure and Review Division of Investment Management United States Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 RE: Sycuan Funds (the "Trust"); File Nos. 811-21401 and 333-107049 Dear Ms. Delano: Please find below Trust’s responses to oral comments from the staff received on January 5, 2005. For your convenience, I have summarized the staff’s comments. 1. Comment: In future filings please include the Item 22(b)(6) under the Trustees Table in annual reports. Response: The Trust will include Item 22(b)(6) in future annual reports. 2. Comment: In future shareholder reports, please enhance the disclosure regarding fair valuation. Response: The Trust’s Board of Trustees has adopted Good Faith Pricing Guidelines that discuss the factors considered when fair valuing investments. Some of these factors will be disclosed in the Notes to Financial Statements in future shareholder reports to enhance the disclosure. 3. Comment: Why does footnote *** say “based on average daily net assets” in the 2004 annual report. Response: The footnote was inadvertently added to the annual report, and will be removed from future reports. 4. Other Comments: The staff requested that the Trust provide a statement in response to the generic “Tandy” letter. Response: The Trust hereby acknowledges that the fund is responsible for the adequacy and accuracy of the disclosure in the filings reviewed by the staff; 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 Trust may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. __________________________________ If you have any questions or additional comments, please call the undersigned at 619-444-4043. Respectfully, /s/ Jeff Provence Jeff Provence Treasurer, Sycuan Funds