SEC Company Response from AXA ENTERPRISE FUNDS TRUST (CIK 0001312580) — Jun 3, 2005
AXA ENTERPRISE FUNDS TRUST (CIK 0001312580)
Date: June 3, 2005 · CIK: 0001312580 · Accession: 0000898432-05-000468
AI Filing Summary & Sentiment
File numbers found in text: 333-121788, 811-21695
Letter
June 3, 2005 VIA EDGAR AND E-MAIL -------------------- Linda B. Stirling, Esq. U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549
Re: Responses to Comments on Pre-Effective Amendment No. 1 to the Registration Statement on Form N-1A of AXA Enterprise Funds Trust (File Nos. 333-121788 and 811-21695) ---------------------------------------------------------------------------
Dear Ms. Stirling:
On behalf of the above-referenced registrant, set forth below are the comments that you provided on May 27, 2005 concerning Pre-Effective Amendment No. 1 to the Registration Statement on Form N-1A (the "Registration Statement") of AXA Enterprise Funds Trust (the "Trust"), which was filed with the U.S. Securities and Exchange Commission (the "SEC") on May 13, 2005, and the Trust's responses thereto. Your comments are set forth in italics and are followed by the Trust's responses, which are reflected in the attached changed pages from the Registration Statement. Unless otherwise noted, defined terms have the same meaning as in the Registration Statement.
STATEMENT OF ADDITIONAL INFORMATION -----------------------------------
APPENDIX C ----------
(a) WITH REGARDS TO BARROW HANLEY MEWHINNEY & STRAUSS, INC.'S PORTFOLIO MANAGER DISCLOSURE, CLARIFY WHETHER PORTFOLIO MANAGER COMPENSATION IS BASED ON THE PERFORMANCE OF THE FUND. ALSO DISCLOSE ANY DIFFERENCES BETWEEN THE METHODS USED TO DETERMINE THE PORTFOLIO MANAGERS' COMPENSATION WITH RESPECT TO THE FUND AND ANY OTHER ACCOUNTS (E.G. IF THE MANAGER RECEIVES PART OF AN ADVISORY FEE THAT IS BASED ON PERFORMANCE WITH RESPECT TO SOME ACCOUNTS BUT NOT THE FUND, THIS MUST BE DISCLOSED).
The Trust has made the requested change.
<PAGE>
KIRKPATRICK & LOCKHART NICHOLSON GRAHAM LLP
Linda B. Stirling, Esq. June 3, 2005 Page 2
(b) WITH REGARDS TO ALLIANCE CAPITAL MANAGEMENT L.P.'S PORTFOLIO MANAGER DISCLOSURE, DISCLOSE THE CRITERIA USED TO DETERMINE THE LEVEL OF COMPENSATION WITHIN EACH OF THE FIVE CATEGORIES OF COMPENSATION DESCRIBED IN THE FIRST PARAGRAPH UNDER "COMPENSATION OF INVESTMENT PROFESSIONALS."
The Trust has made the requested change.
* * * * *
The Trust acknowledges that: (1) it is responsible for the adequacy and accuracy of the disclosure in the Registration Statement; (2) staff comments or changes to disclosure in response to staff comments in the Registration Statement reviewed by the staff do not foreclose the SEC from taking any action with respect to the Registration Statement; and (3) it may not assert staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.
Should you have any further comments on these matters, or any questions, please contact Arthur J. Brown at (202) 778-9046 or me at (202) 778-9351.
Sincerely,
/s/ Mark C. Amorosi
Show Raw Text
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KIRKPATRICK & LOCKHART NICHOLSON GRAHAM LLP 1800 Massachusetts Avenue, N.W.
Suite 200
Washington, DC 20036-1221
202.778.9000
Fax 202.778.9100
www.klng.com
Mark C. Amorosi
202.778.9351
Fax: 202.778.9100
mamorosi@klng.com
June 3, 2005
VIA EDGAR AND E-MAIL
--------------------
Linda B. Stirling, Esq.
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Responses to Comments on Pre-Effective Amendment No. 1 to the Registration
Statement on Form N-1A of AXA Enterprise Funds Trust (File Nos. 333-121788
and 811-21695)
---------------------------------------------------------------------------
Dear Ms. Stirling:
On behalf of the above-referenced registrant, set forth below are the comments
that you provided on May 27, 2005 concerning Pre-Effective Amendment No. 1 to
the Registration Statement on Form N-1A (the "Registration Statement") of AXA
Enterprise Funds Trust (the "Trust"), which was filed with the U.S. Securities
and Exchange Commission (the "SEC") on May 13, 2005, and the Trust's responses
thereto. Your comments are set forth in italics and are followed by the Trust's
responses, which are reflected in the attached changed pages from the
Registration Statement. Unless otherwise noted, defined terms have the same
meaning as in the Registration Statement.
STATEMENT OF ADDITIONAL INFORMATION
-----------------------------------
APPENDIX C
----------
(a) WITH REGARDS TO BARROW HANLEY MEWHINNEY & STRAUSS, INC.'S PORTFOLIO
MANAGER DISCLOSURE, CLARIFY WHETHER PORTFOLIO MANAGER COMPENSATION IS
BASED ON THE PERFORMANCE OF THE FUND. ALSO DISCLOSE ANY DIFFERENCES
BETWEEN THE METHODS USED TO DETERMINE THE PORTFOLIO MANAGERS'
COMPENSATION WITH RESPECT TO THE FUND AND ANY OTHER ACCOUNTS (E.G. IF
THE MANAGER RECEIVES PART OF AN ADVISORY FEE THAT IS BASED ON
PERFORMANCE WITH RESPECT TO SOME ACCOUNTS BUT NOT THE FUND, THIS MUST
BE DISCLOSED).
The Trust has made the requested change.
<PAGE>
KIRKPATRICK & LOCKHART NICHOLSON GRAHAM LLP
Linda B. Stirling, Esq.
June 3, 2005
Page 2
(b) WITH REGARDS TO ALLIANCE CAPITAL MANAGEMENT L.P.'S PORTFOLIO MANAGER
DISCLOSURE, DISCLOSE THE CRITERIA USED TO DETERMINE THE LEVEL OF
COMPENSATION WITHIN EACH OF THE FIVE CATEGORIES OF COMPENSATION
DESCRIBED IN THE FIRST PARAGRAPH UNDER "COMPENSATION OF INVESTMENT
PROFESSIONALS."
The Trust has made the requested change.
* * * * *
The Trust acknowledges that: (1) it is responsible for the adequacy and accuracy
of the disclosure in the Registration Statement; (2) staff comments or changes
to disclosure in response to staff comments in the Registration Statement
reviewed by the staff do not foreclose the SEC from taking any action with
respect to the Registration Statement; and (3) it may not assert staff comments
as a defense in any proceeding initiated by the SEC or any person under the
federal securities laws of the United States.
Should you have any further comments on these matters, or any questions, please
contact Arthur J. Brown at (202) 778-9046 or me at (202) 778-9351.
Sincerely,
/s/ Mark C. Amorosi
Mark C. Amorosi
Attachment
cc: Patricia Louie, Esq.
AXA Equitable Life Insurance Company
Arthur J. Brown, Esq.
Kirkpatrick & Lockhart Nicholson Graham LLP
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