Correspondence 0001293210-24-000009 from AMERICAN CENTURY ASSET ALLOCATION PORTFOLIOS, INC. (CIK 0001293210)
AMERICAN CENTURY ASSET ALLOCATION PORTFOLIOS, INC. (CIK 0001293210)
Date: May 3, 2024 · CIK: 0001293210 · Accession: 0001293210-24-000009
AI Filing Summary & Sentiment
File numbers found in text: 811-03706, 811-21591, 811-23305
Letter
VIA EDGAR American Century California Tax-Free & Municipal Funds (File No. 811-03706) American Century ETF Trust (File No. 811-23305) (collectively, the “Registrants”)
Re: American Century Asset Allocation Portfolios, Inc. (File No. 811-21591)
Dear Ms. Rotter:
This letter responds to the comments you provided during our phone conversation on April 3, 2024, regarding your Sarbanes-Oxley review of various funds (“Funds”) of the above-referenced Registrants. The Funds are listed on Appendix A hereto. For your convenience, we have restated each comment prior to our responses.
1.Comment: The response to Item C.7.k on Form N-CEN filed on 11/9/2023 was not selected. Please explain in correspondence whether the response to the question is correct. If not, confirm going forward that it will be selected if applicable. This comment applies to Focused Dynamic Growth ETF, Focused Large Cap Value ETF, Mid Cap Growth Impact ETF, Sustainable Equity ETF, and Sustainable Growth ETF.
Response: The response to the question is correct. These Funds did not rely on Rule 6c-11 during the period; rather, they operated pursuant to exemptive relief granted in Orders IC-33620 and IC-33862. The Funds’ reliance on these orders was reported in the response to Item B.15.a. on Form N-CEN.
2.Comment: For those Funds with a portfolio turnover greater than 100%, please explain in correspondence why portfolio turnover risk is not disclosed as a principal risk of the Fund. Examples include Low Volatility ETF, U.S. Quality Value ETF, Avantis Core Fixed Income ETF and Avantis Core Fixed Income Fund.
Response: We plan to revise the prospectus disclosure to include portfolio turnover risk as a principal risk in these Funds’ next annual registration statement amendments.
3.Comment: For those Funds that have a unitary fee structure whereby the advisor is obligated to pay service providers on behalf of the fund, please describe in correspondence if the advisor is current with all payments to fund service providers. Additionally, describe if the agreements filed with the Commission contain provisions whereby the fund is contractually obligated to pay such service providers.
Ms. Mindy Rotter
May 3, 2024
Page 2
Response: The advisor is current in all payments to Fund service providers. For the services it provides to the Funds, the advisor receives a unified management fee based on a percentage of the daily net assets of the Fund. Under each Fund’s management agreement, the advisor is contractually obligated to pay all expenses of managing and operating the Fund, with limited exceptions (which are disclosed in each Fund’s prospectus). Generally, the advisor enters into agreements with Fund service providers, and in most cases the Funds are not parties to these agreements and are not contractually obligated to pay any service providers.
The Funds are party to a Master Custodian Agreement with State Street Bank and Trust Company (the “custodian”), under which the custodian is “entitled to reasonable compensation for its services and expenses as custodian, as agreed upon from time to time between each Fund . . . and the custodian.” As noted above, the advisor is contractually obligated to pay these expenses on behalf of each Fund, and in practice the advisor pays the custodian directly for the services provided to the Funds; the Funds do not make payments to the custodian.
4.Comment: Please confirm in correspondence whether each non-diversified Fund continues to maintain its non-diversified status. The Staff notes that if any of the Funds have been operating as a diversified fund for more than three years, that Fund will require shareholder approval prior to changing its status back to a non-diversified fund. This comment applies to all non-diversified Funds.
Response: American Century Quality Convertible Securities ETF and American Century Quality Preferred ETF ceased to maintain their non-diversified status in the first quarter of 2024. Their change in status from non-diversified to diversified will be reflected in their next annual registration statement amendment, and we acknowledge that changing their status back to non-diversified would require shareholder approval. The other non-diversified Funds continue to maintain their non-diversified status.
5.Comment: Please explain in correspondence why the Fund has not disclosed that it follows the accounting and reporting requirements of investment companies under ASC 946. This comment applies to all Funds.
Response: The Funds make the disclosures stipulated in ASC-946-10-50-1 in the first paragraph of Note 2. While the ASC reference is not specifically included, the Funds make the following statement: “Each fund is an investment company and follows accounting and reporting guidance in accordance with accounting principles generally accepted in the United States of America.”
If you have any questions regarding the above responses, please contact the undersigned at evan_johnson@americancentury.com or (816) 340-3267.
Sincerely,
/s/ Evan C. Johnson
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CORRESP 1 filename1.htm Document VIA EDGAR May 3, 2024 Ms. Mindy Rotter U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-2000 Re: American Century Asset Allocation Portfolios, Inc. (File No. 811-21591) American Century California Tax-Free & Municipal Funds (File No. 811-03706) American Century ETF Trust (File No. 811-23305) (collectively, the “Registrants”) Dear Ms. Rotter: This letter responds to the comments you provided during our phone conversation on April 3, 2024, regarding your Sarbanes-Oxley review of various funds (“Funds”) of the above-referenced Registrants. The Funds are listed on Appendix A hereto. For your convenience, we have restated each comment prior to our responses. 1.Comment: The response to Item C.7.k on Form N-CEN filed on 11/9/2023 was not selected. Please explain in correspondence whether the response to the question is correct. If not, confirm going forward that it will be selected if applicable. This comment applies to Focused Dynamic Growth ETF, Focused Large Cap Value ETF, Mid Cap Growth Impact ETF, Sustainable Equity ETF, and Sustainable Growth ETF. Response: The response to the question is correct. These Funds did not rely on Rule 6c-11 during the period; rather, they operated pursuant to exemptive relief granted in Orders IC-33620 and IC-33862. The Funds’ reliance on these orders was reported in the response to Item B.15.a. on Form N-CEN. 2.Comment: For those Funds with a portfolio turnover greater than 100%, please explain in correspondence why portfolio turnover risk is not disclosed as a principal risk of the Fund. Examples include Low Volatility ETF, U.S. Quality Value ETF, Avantis Core Fixed Income ETF and Avantis Core Fixed Income Fund. Response: We plan to revise the prospectus disclosure to include portfolio turnover risk as a principal risk in these Funds’ next annual registration statement amendments. 3.Comment: For those Funds that have a unitary fee structure whereby the advisor is obligated to pay service providers on behalf of the fund, please describe in correspondence if the advisor is current with all payments to fund service providers. Additionally, describe if the agreements filed with the Commission contain provisions whereby the fund is contractually obligated to pay such service providers. Ms. Mindy Rotter May 3, 2024 Page 2 Response: The advisor is current in all payments to Fund service providers. For the services it provides to the Funds, the advisor receives a unified management fee based on a percentage of the daily net assets of the Fund. Under each Fund’s management agreement, the advisor is contractually obligated to pay all expenses of managing and operating the Fund, with limited exceptions (which are disclosed in each Fund’s prospectus). Generally, the advisor enters into agreements with Fund service providers, and in most cases the Funds are not parties to these agreements and are not contractually obligated to pay any service providers. The Funds are party to a Master Custodian Agreement with State Street Bank and Trust Company (the “custodian”), under which the custodian is “entitled to reasonable compensation for its services and expenses as custodian, as agreed upon from time to time between each Fund . . . and the custodian.” As noted above, the advisor is contractually obligated to pay these expenses on behalf of each Fund, and in practice the advisor pays the custodian directly for the services provided to the Funds; the Funds do not make payments to the custodian. 4.Comment: Please confirm in correspondence whether each non-diversified Fund continues to maintain its non-diversified status. The Staff notes that if any of the Funds have been operating as a diversified fund for more than three years, that Fund will require shareholder approval prior to changing its status back to a non-diversified fund. This comment applies to all non-diversified Funds. Response: American Century Quality Convertible Securities ETF and American Century Quality Preferred ETF ceased to maintain their non-diversified status in the first quarter of 2024. Their change in status from non-diversified to diversified will be reflected in their next annual registration statement amendment, and we acknowledge that changing their status back to non-diversified would require shareholder approval. The other non-diversified Funds continue to maintain their non-diversified status. 5.Comment: Please explain in correspondence why the Fund has not disclosed that it follows the accounting and reporting requirements of investment companies under ASC 946. This comment applies to all Funds. Response: The Funds make the disclosures stipulated in ASC-946-10-50-1 in the first paragraph of Note 2. While the ASC reference is not specifically included, the Funds make the following statement: “Each fund is an investment company and follows accounting and reporting guidance in accordance with accounting principles generally accepted in the United States of America.” If you have any questions regarding the above responses, please contact the undersigned at evan_johnson@americancentury.com or (816) 340-3267. Sincerely, /s/ Evan C. Johnson Evan C. Johnson Assistant Secretary Ms. Mindy Rotter May 3, 2024 Page 3 APPENDIX A Count Series ID FYE File # Series Name Registrant Name 1 S000071093 7/31/2023 811-21591 One Choice® Blend+ 2015 Portfolio American Century Asset Allocation Portfolios, Inc. 2 S000071096 7/31/2023 811-21591 One Choice® Blend+ 2020 Portfolio American Century Asset Allocation Portfolios, Inc. 3 S000071097 7/31/2023 811-21591 One Choice® Blend+ 2025 Portfolio American Century Asset Allocation Portfolios, Inc. 4 S000071098 7/31/2023 811-21591 One Choice® Blend+ 2030 Portfolio American Century Asset Allocation Portfolios, Inc. 5 S000071099 7/31/2023 811-21591 One Choice® Blend+ 2035 Portfolio American Century Asset Allocation Portfolios, Inc. 6 S000071100 7/31/2023 811-21591 One Choice® Blend+ 2040 Portfolio American Century Asset Allocation Portfolios, Inc. 7 S000071101 7/31/2023 811-21591 One Choice® Blend+ 2045 Portfolio American Century Asset Allocation Portfolios, Inc. 8 S000071102 7/31/2023 811-21591 One Choice® Blend+ 2050 Portfolio American Century Asset Allocation Portfolios, Inc. 9 S000071103 7/31/2023 811-21591 One Choice® Blend+ 2055 Portfolio American Century Asset Allocation Portfolios, Inc. 10 S000071094 7/31/2023 811-21591 One Choice® Blend+ 2060 Portfolio American Century Asset Allocation Portfolios, Inc. 11 S000071095 7/31/2023 811-21591 One Choice® Blend+ 2065 Portfolio American Century Asset Allocation Portfolios, Inc. 12 S000005390 7/31/2023 811-21591 One Choice® Portfolio: Very Conservative American Century Asset Allocation Portfolios, Inc. 13 S000005398 7/31/2023 811-21591 One Choice® Portfolio: Conservative American Century Asset Allocation Portfolios, Inc. 14 S000005397 7/31/2023 811-21591 One Choice® Portfolio: Moderate American Century Asset Allocation Portfolios, Inc. 15 S000005396 7/31/2023 811-21591 One Choice® Portfolio: Aggressive American Century Asset Allocation Portfolios, Inc. 16 S000005395 7/31/2023 811-21591 One Choice® Portfolio: Very Aggressive American Century Asset Allocation Portfolios, Inc. 17 S000005394 7/31/2023 811-21591 One Choice® In Retirement Portfolio American Century Asset Allocation Portfolios, Inc. 18 S000005391 7/31/2023 811-21591 One Choice® 2025 Portfolio American Century Asset Allocation Portfolios, Inc. 19 S000022361 7/31/2023 811-21591 One Choice® 2030 Portfolio American Century Asset Allocation Portfolios, Inc. 20 S000005392 7/31/2023 811-21591 One Choice® 2035 Portfolio American Century Asset Allocation Portfolios, Inc. 21 S000022362 7/31/2023 811-21591 One Choice® 2040 Portfolio American Century Asset Allocation Portfolios, Inc. 22 S000005393 7/31/2023 811-21591 One Choice® 2045 Portfolio American Century Asset Allocation Portfolios, Inc. Ms. Mindy Rotter May 3, 2024 Page 4 Count Series ID FYE File # Series Name Registrant Name 23 S000022363 7/31/2023 811-21591 One Choice® 2050 Portfolio American Century Asset Allocation Portfolios, Inc. 24 S000031554 7/31/2023 811-21591 One Choice® 2055 Portfolio American Century Asset Allocation Portfolios, Inc. 25 S000050745 7/31/2023 811-21591 One Choice® 2060 Portfolio American Century Asset Allocation Portfolios, Inc. 26 S000069540 7/31/2023 811-21591 One Choice® 2065 Portfolio American Century Asset Allocation Portfolios, Inc. 27 S000005667 8/31/2023 811-03706 California High-Yield Municipal Fund American Century California Tax-Free & Municipal Funds 28 S000005668 8/31/2023 811-03706 California Intermediate-Term Tax-Free Bond Fund American Century California Tax-Free & Municipal Funds 29 S000005671 8/31/2023 811-03706 California Tax-Free Money Market Fund American Century California Tax-Free & Municipal Funds 30 S000060785 8/31/2023 811-23305 American Century Diversified Corporate Bond ETF American Century ETF Trust 31 S000063026 8/31/2023 811-23305 American Century Diversified Municipal Bond ETF American Century ETF Trust 32 S000072411 8/31/2023 811-23305 American Century Emerging Markets Bond ETF American Century ETF Trust 33 S000079797 8/31/2023 811-23305 American Century Multisector Floating Income ETF American Century ETF Trust 34 S000072410 8/31/2023 811-23305 American Century Multisector Income ETF American Century ETF Trust 35 S000074150 8/31/2023 811-23305 American Century Select High Yield ETF American Century ETF Trust 36 S000077487 8/31/2023 811-23305 American Century Short Duration Strategic Income ETF American Century ETF Trust 37 S000063004 8/31/2023 811-23305 American Century Focused Dynamic Growth ETF American Century ETF Trust 38 S000063005 8/31/2023 811-23305 American Century Focused Large Cap Value ETF American Century ETF Trust 39 S000068306 8/31/2023 811-23305 American Century Mid Cap Growth Impact ETF American Century ETF Trust 40 S000068307 8/31/2023 811-23305 American Century Sustainable Equity ETF American Century ETF Trust 41 S000072412 8/31/2023 811-23305 American Century Sustainable Growth ETF American Century ETF Trust Ms. Mindy Rotter May 3, 2024 Page 5 Count Series ID FYE File # Series Name Registrant Name 42 S000070039 8/31/2023 811-23305 American Century Low Volatility ETF American Century ETF Trust 43 S000070040 8/31/2023 811-23305 American Century Quality Convertible Securities ETF American Century ETF Trust 44 S000070041 8/31/2023 811-23305 American Century Quality Preferred ETF American Century ETF Trust 45 S000062301 8/31/2023 811-23305 American Century Quality Diversified International ETF American Century ETF Trust 46 S000062302 8/31/2023 811-23305 American Century U.S. Quality Growth ETF American Century ETF Trust 47 S000060786 8/31/2023 811-23305 American Century U.S. Quality Value ETF American Century ETF Trust 48 S000077485 8/31/2023 811-23305 Avantis® Inflation Focused Equity ETF American Century ETF Trust 49 S000072999 8/31/2023 811-23305 Avantis® Real Estate ETF American Century ETF Trust 50 S000066458 8/31/2023 811-23305 Avantis® U.S. Equity ETF American Century ETF Trust 51 S000072998 8/31/2023 811-23305 Avantis® U.S. Large Cap Value ETF American Century ETF Trust 52 S000074835 8/31/2023 811-23305 Avantis® U.S. Small Cap Equity ETF American Century ETF Trust 53 S000066459 8/31/2023 811-23305 Avantis® U.S. Small Cap Value ETF American Century ETF Trust 54 S000066454 8/31/2023 811-23305 Avantis® Emerging Markets Equity ETF American Century ETF Trust 55 S000072996 8/31/2023 811-23305 Avantis® Emerging Markets Value ETF American Century ETF Trust 56 S000066456 8/31/2023 811-23305 Avantis® International Equity ETF American Century ETF Trust 57 S000072997 8/31/2023 811-23305 Avantis® International Large Cap Value ETF American Century ETF Trust 58 S000080558 8/31/2023 811-23305 Avantis® International Small Cap Equity ETF American Century ETF Trust 59 S000066457 8/31/2023 811-23305 Avantis® International Small Cap Value ETF American Century ETF Trust 60 S000069304 8/31/2023 811-23305 Avantis® Core Fixed Income ETF American Century ETF Trust 61 S000069305 8/31/2023 811-23305 Avantis® Core Municipal Fixed Income ETF American Century ETF Trust 62 S000069306 8/31/2023 811-23305 Avantis® Short-Term Fixed Income ETF American Century ETF Trust 63 S000066460 8/31/2023 811-23305 Avantis® U.S. Equity Fund American Century ETF Trust 64 S000076521 8/31/2023 811-23305 Avantis® U.S. Large Cap Value Fund American Century ETF Trust Ms. Mindy Rotter May 3, 2024 Page 6 Count Series ID FYE File # Series Name Registrant Name 65 S000066461 8/31/2023 811-23305 Avantis® U.S. Small Cap Value Fund American Century ETF Trust 66 S000066462 8/31/2023 811-23305 Avantis® Emerging Markets Equity Fund American Century ETF Trust 67 S000066463 8/31/2023 811-23305 Avantis® International Equity Fund American Century ETF Trust 68 S000066455 8/31/2023 811-23305 Avantis® International Small Cap Value Fund American Century ETF Trust 69 S000069307 8/31/2023 811-23305 Avantis® Core Fixed Income Fund American Century ETF Trust 70 S000069309 8/31/2023 811-23305 Avantis® Short-Term Fixed Income Fund American Century ETF Trust 71 S000075383 8/31/2023 811-23305 Avantis® Responsible U.S. Equity ETF American Century ETF Trust 72 S000075381 8/31/2023 811-23305 Avantis® Responsible Emerging Markets Equity ETF American Century ETF Trust 73 S000075382 8/31/2023 811-23305 Avantis® Responsible International Equity ETF American Century ETF Trust 74 S000077486 8/31/2023 811-23305 Avantis® All Equity Markets ETF American Century ETF Trust 75 S000080557 8/31/2023 811-23305 Avantis® All Equity Markets Value ETF American Century ETF Trust 76 S000080560 8/31/2023 811-23305 Avantis® All International Markets Equity ETF American Century ETF Trust 77 S000080561 8/31/2023 811-23305 Avantis® All International Markets Value ETF American Century ETF Trust 78 S000080559 8/31/2023 811-23305 Avantis® Moderate Allocation ETF American Century ETF Trust