SEC Company Response from Cortina Funds, Inc. (CIK 0001289519) — Jun 3, 2004
Cortina Funds, Inc. (CIK 0001289519)
Date: June 3, 2004 · CIK: 0001289519 · Accession: 0001193125-04-098125
AI Filing Summary & Sentiment
File numbers found in text: 811-21580
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BELL, BOYD & LLOYD LLC
Three First National Plaza
70 West Madison Street, Suite 3300
Chicago, Illinois 60602-4207
312 372-1121
Fax 312 827-8000
June 3, 2004
BY EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Cortina Funds, Inc.
1933 Act Registration No. 33-115299
1940 Act Registration No. 811-21580
Ladies and Gentlemen:
On May 7, 2004, on behalf of Cortina Funds, Inc. (the "Fund"), we filed via
EDGAR the Fund's initial registration statement on Form N-1A, which contained
two prospectuses: the Investor Shares prospectus (the "Investor Prospectus") and
the Institutional Shares prospectus (the "Institutional Prospectus"). On June 2,
2004, we spoke with Mr. Randolph S. Koch, an examiner with your Division of
Investment Management assigned to the Fund, regarding requesting selective
review for the Institutional Prospectus.
REQUEST FOR SELECTIVE REVIEW OF THE INSTITUTIONAL PROSPECTUS. We are
requesting selective review of the Institutional Prospectus. The Institutional
Prospectus contains only immaterial differences from the Investor Prospectus,
except that (page numbers refer to the Institutional Prospectus):
1. the Institutional Shares charge no 12b-1 fees (see cover page and
page 5);
2. the maximum total annual fund operating expenses (after reimbursement
by the Fund's investment adviser) for the Institutional Shares is
anticipated to be lower than the maximum total annual fund operating
expenses (after reimbursement) for the Investor Shares by 0.25%, which
percentage is equivalent to the 12b-1 fees charged to investor shares
(see page 5);
3. the minimum investment amounts are significantly higher for
Institutional Shares (see cover page and pages 7 and 9);
4. certain account types described in the Institutional Prospectus are
not available in the Investor Prospectus, and vice versa; for example,
the Institutional Prospectus
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Securities and Exchange Commission
June 3, 2004
Page 2
describes account types for trusts, employee benefit and profit
sharing plans but does not describe account types for minors or
individual retirement accounts (see page 8); and
5. under "How to Buy Shares," two paragraphs were added providing
pertinent details for an Institutional Shares' investor (see page 10).
ADDITIONAL FILINGS AND ANTICIPATED EFFECTIVE DATE. The Fund will file a
pre-effective amendment to the initial registration statement - with a
designated effective date of July 1, 2004 - before the registration statement
becomes effective under the Securities Act of 1933.
COMMENTS. Please direct any comments to the undersigned at 312-781-6014 or
Alan Goldberg at 312-807-4227.
Very truly yours,
/s/ Robert Y. Tseng
Robert Y. Tseng
Copy to Ms. Lori K. Hoch
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