Correspondence 0001398344-25-005833 from Horizon Funds (CIK 0001643174)
Horizon Funds (CIK 0001643174)
Date: March 21, 2025 · CIK: 0001643174 · Accession: 0001398344-25-005833
AI Filing Summary & Sentiment
File numbers found in text: 333-205411, 811-23063
Letter
Re: Horizon Funds Response to Staff’s Comments to Post-Effective Amendment No. 45
March 21, 2025
FILED VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
to Registration Statement on Form N-1A Filed January 28, 2025
(File Nos. 333-205411 and 811-23063)
Ladies and Gentlemen:
We are submitting this correspondence on behalf of our client, Horizon Funds (the “Trust”). Ms. Deborah O’Neal of the staff (the “Staff”) of the Securities and Exchange Commission provided comments on March 12, 2024, regarding Post-Effective Amendment No. 45 (the “Amendment”) to the above-referenced registration statement on Form N-1A (the “Registration Statement”) under the Securities Act of 1933 and the Investment Company Act of 1940.
The following are the Staff’s comment to the Registration Statement and the Trust’s response:
1. Please provide completed fee tables, cost examples, and performance presentations for all funds at least 1 week prior to effectiveness.
RESPONSE: Please see completed fee tables, cost examples, and performance presentations for each Fund attached as Exhibit A.
Thank you for your comments. Please contact me at 336-607-7512 if you have any additional questions or comments.
Very truly yours,
/s/ Jeffrey Skinner
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CORRESP
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filename1.htm
March 21, 2025
FILED VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Horizon Funds Response to Staff’s Comments to Post-Effective Amendment No. 45
to Registration Statement on Form N-1A Filed
January 28, 2025
(File Nos. 333-205411 and 811-23063)
Ladies and Gentlemen:
We are submitting this correspondence
on behalf of our client, Horizon Funds (the “Trust”). Ms. Deborah O’Neal of the staff (the “Staff”)
of the Securities and Exchange Commission provided comments on March 12, 2024, regarding Post-Effective Amendment No. 45 (the “Amendment”)
to the above-referenced registration statement on Form N-1A (the “Registration Statement”) under the Securities
Act of 1933 and the Investment Company Act of 1940.
The following are the Staff’s
comment to the Registration Statement and the Trust’s response:
1. Please provide completed fee tables, cost examples, and performance presentations for all funds at
least 1 week prior to effectiveness.
RESPONSE: Please see completed fee
tables, cost examples, and performance presentations for each Fund attached as Exhibit A.
Thank you for your comments. Please contact me at 336-607-7512
if you have any additional questions or comments.
Very truly yours,
/s/ Jeffrey Skinner
Jeffrey Skinner
Exhibit A
HORIZON ACTIVE ASSET ALLOCATION FUND
Fees and Expenses of the Allocation Fund
This table describes the fees and expenses that you
may pay if you buy, hold and sell shares of the Allocation Fund. You may pay other fees, such as brokerage commissions and other fees
to financial intermediaries, which are not reflected in the tables and examples below.
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your
investment)
Advisor
Class
Institutional
Class
Investor
Class
Management Fees
0.99%
0.99%
0.99%
Distribution and/or Service (12b-1) Fees
0.25%
None
None
Other Expenses (1)
0.12%
0.12%
0.12%
Interest Expense
0.01%
0.01%
0.01%
Remainder of Other Expenses
0.11%
0.11%
0.11%
Shareholder Servicing Expenses
None
None
0.10%
Acquired Fund Fees and Expenses(2)
0.13%
0.13%
0.13%
Total Annual Fund Operating Expenses(3)
1.49%
1.24%
1.34%
(1) “Other Expenses” have been restated to reflect current expenses.
(2) This number represents the combined total fees and operating expenses of the underlying funds owned by
the Allocation Fund and is not a direct expense incurred by the Allocation Fund or deducted from Fund assets. Since this number does not
represent a direct operating expense of the Allocation Fund, the operating expenses set forth in the Allocation Fund’s financial
highlights do not include this figure.
(3) Note that the Total Annual Fund Operating Expenses shown in the table above differ from the ratio of expenses
to average net assets included in the Allocation Fund’s financial highlights section of the Prospectus. The financial highlights
reflect operating expenses and include expense reductions from securities lending but exclude indirect expenses. The ratio of expenses
to average net assets in the financial highlights also includes interest expense incurred during the 2024 fiscal year.
Example. This Example is intended to help you
compare the cost of investing in the Allocation Fund with the cost of investing in other mutual funds. The Example assumes that you invest
$10,000 in the Allocation Fund for the time periods indicated and then redeem all of your shares at the end of those periods. The Example
also assumes that your investment has a 5% return each year and that the Allocation Fund’s operating expenses remain the same. Although
your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year
3 Years
5 Years
10 Years
Advisor Class
$152
$471
$813
$1,779
Institutional Class
$126
$393
$681
$1,500
Investor Class
$136
$425
$734
$1,613
Calendar Year Returns as of December 31
Investor Class
During the period shown in the bar chart, the best
performance for a quarter was 18.28% (for the quarter ended June 30, 2020). The worst performance was -22.34% (for the quarter ended March
31, 2020).
Active Asset Allocation Fund
Average Annual Total Returns
For the periods ended December 31, 2024
One Year
Five Years
Ten Years*
Since Inception
of Class*
Investor Class
Return Before Taxes
12.44%
8.76%
7.44%
8.59%
Return After Taxes on Distributions
6.61%
6.14%
5.26%
6.40%
Return After Taxes on Distributions and Sale of Fund Shares
8.67%
6.08%
5.11%
6.08%
Advisor Class
Return Before Taxes
12.36%
8.61%
N/A
8.80%
Institutional Class
Return Before Taxes
12.62%
8.89%
N/A
9.44%
S&P 500 Total Return Index (reflects no deduction for fees, expenses or taxes)
25.02%
14.53%
13.10%
14.46%
S&P Global BMI ex-US Index (reflects no deduction for fees, expenses or taxes)
5.50%
4.14%
5.00%
5.50%
* Investor Class shares commenced operations on January 31, 2012. Advisor Class shares commenced operations
on September 4, 2015, and Institutional Class shares commenced operations on September 9, 2016. Index information is since inception of
Investor Class shares.
HORIZON ACTIVE RISK ASSIST® FUND
Fees and Expenses of the Risk Assist Fund
This table describes the fees and expenses that you may pay if you buy,
hold and sell shares of the Risk Assist Fund. You may pay other fees, such as brokerage commissions and other fees to financial intermediaries,
which are not reflected in the tables and examples below.
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your
investment)
Advisor
Class
Institutional
Class
Investor
Class
Management Fees
0.99%
0.99%
0.99%
Distribution and/or Service (12b-1) Fees
0.25%
None
None
Other Expenses(1)
0.10%
0.10%
0.10%
Shareholder Servicing Expenses
None
None
0.10%
Acquired Fund Fees and Expenses(2)
0.09%
0.09%
0.09%
Total Annual Fund Operating Expenses(3)
1.43%
1.18%
1.28%
(1) “Other Expenses” have been restated to reflect current expenses.
(2) This number represents the combined total fees and operating expenses of the underlying funds owned by
the Risk Assist Fund and is not a direct expense incurred by the Risk Assist Fund or deducted from Fund assets. Since this number does
not represent a direct operating expense of the Risk Assist Fund, the operating expenses set forth in the Risk Assist Fund’s financial
highlights do not include this figure.
(3) Note that the Total Annual Fund Operating Expenses shown in the table above differ from the ratio of expenses
to average net assets included in the Risk Assist Fund’s financial highlights section of the Prospectus. The financial highlights
reflect operating expenses and include expense reductions from securities lending but exclude indirect expenses. The ratio of expenses
to average net assets in the financial highlights also includes interest expense incurred during the 2024 fiscal year.
Example: This Example is intended to help you
compare the cost of investing in the Risk Assist Fund with the cost of investing in other mutual funds. The Example assumes that you invest
$10,000 in the Risk Assist Fund for the time periods indicated and then redeem all of your shares at the end of those periods. The Example
also assumes that your investment has a 5% return each year and that the Risk Assist Fund’s operating expenses remain the same.
Although your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year
3 Years
5 Years
10 Years
Advisor Class
$146
$452
$782
$1,713
Institutional Class
$120
$375
$649
$1,432
Investor Class
$130
$406
$702
$1,545
Calendar Year Returns as of December 31
Investor Class
During the period shown in the bar chart, the best performance for a quarter
was 13.17% (for the quarter ended December 31, 2020). The worst performance was -16.67% (for the quarter ended March 31, 2020).
Active Risk Assist Fund
Average Annual Total Returns
For the periods ended December 31, 2024
One Year
Five Years
Ten Years
Since Inception
of Class*
Investor Class
Return Before Taxes
13.62%
6.09%
4.88%
4.88%
Return After Taxes on Distributions
11.12%
4.92%
3.93%
3.96%
Return After Taxes on Distributions and Sale of Fund Shares
9.91%
4.51%
3.60%
3.61%
Advisor Class
Return Before Taxes
13.44%
5.92%
N/A
5.88%
Institutional Class
Return Before Taxes
13.78%
6.20%
N/A
6.63%
S&P 500 Total Return Index (reflects no deduction for fees, expenses or taxes)
25.02%
14.53%
13.10%
13.02%
S&P Global BMI ex-US Index (reflects no deduction for fees, expenses or taxes)
5.50%
4.14%
5.00%
3.94%
Bloomberg Aggregate Bond Index (reflects no deduction for fees, expenses or taxes)
1.25%
-0.33%
1.35%
1.41%
* Investor Class shares commenced operations on August 29, 2014. Advisor Class shares commenced operations
on September 4, 2015, and Institutional Class shares commenced operations on September 9, 2016. Index information is since inception of
Investor Class shares.
HORIZON ACTIVE INCOME FUND
Fees and Expenses of the Income Fund
This table describes the fees and expenses that you
may pay if you buy, hold and sell shares of the Income Fund. You may pay other fees, such as brokerage commissions and other fees to
financial intermediaries, which are not reflected in the tables and examples below.
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your
investment)
Advisor
Class
Institutional
Class
Investor
Class
Management Fees
0.77%
0.77%
0.77%
Distribution and/or Service (12b-1) Fees
0.25%
None
None
Other Expenses
0.16%
0.16%
0.16%
Shareholder Servicing Expenses
None
None
0.10%
Acquired Fund Fees and Expenses(1)
0.26%
0.26%
0.26%
Total Annual Fund Operating Expenses(2)
1.44%
1.19%
1.29%
(1) This number represents the combined total fees and operating expenses of the underlying funds owned by
the Income Fund and is not a direct expense incurred by the Income Fund or deducted from Fund assets. Since this number does not represent
a direct operating expense of the Income Fund, the operating expenses set forth in the Income Fund’s financial highlights do not
include this figure.
(2) Note that the Total Annual Fund Operating Expenses shown in the table above differ from the ratio of expenses
to average net assets included in the Income Fund’s financial highlights section of the Prospectus. The financial highlights reflect
operating expenses and include expense reductions from securities lending but exclude indirect expenses.
Example. This Example is intended to help you
compare the cost of investing in the Income Fund with the cost of investing in other mutual funds. The Example assumes that you invest
$10,000 in the Income Fund for the time periods indicated and then redeem all of your shares at the end of those periods. The Example
also assumes that your investment has a 5% return each year and that the Income Fund’s operating expenses remain the same. Although
your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year
3 Years
5 Years
10 Years
Advisor Class
$147
$456
$787
$1,724
Institutional Class
$121
$378
$654
$1,443
Investor Class
$131
$409
$708
$1,556
Calendar Year Returns as of December 31
Investor Class
During the period shown in the bar chart, the best
performance for a quarter was 7.04% (for the quarter ended December 31, 2023). The worst performance was -6.59% (for the quarter ended
March 31, 2022).
Active Income Fund
Average Annual Total Returns
For the periods ended December 31, 2024
One Year
Five Years
Ten Years
Since Inception
of Class*
Investor Class
Return Before Taxes
1.79%
-0.58%
0.19%
0.40%
Return After Taxes on Distributions
0.05%
-1.65%
-0.80%
-0.54%
Return After Taxes on Distributions and Sale of Fund Shares
1.05%
-0.87%
-0.24%
-0.06%
Advisor Class
Return Before Taxes
1.60%
-0.75%
N/A
-0.25%
Institutional Class
Return Before Taxes
1.78%
-0.51%
N/A
0.15%
Bloomberg Aggregate Bond Index (reflects no deduction for fees, expenses or taxes)
1.25%
-0.33%
1.35%
1.71%
* Investor Class shares commenced operations on September 30, 2013. Advisor Class shares commenced operations
on February 8, 2016, and Institutional Class shares commenced operations on September 9, 2016. Index information is since inception of
Investor Class shares.
HORIZON EQUITY PREMIUM INCOME FUND
Fees and Expenses of the Equity Premium Income Fund
This table describes the fees and expenses that you
may pay if you buy, hold and sell shares of the Equity Premium Income Fund. You may pay other fees, such as brokerage commissions and
other fees to financial intermediaries, which are not reflected in the tables and examples below.
Annual Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your
investment)
Advisor
Class
Institutional
Class
Investor
Class
Management Fees
0.75%
0.75%
0.75%
Distribution and/or Service (12b-1) Fees
0.25%
None
0.10%
Other Expenses(1)
0.24%
0.24%
0.24%
Total Annual Fund Operating Expenses(2)
1.24%
0.99%
1.09%
(1) “Other Expenses” have been restated to reflect current expenses and are estimated for the
current fiscal year for the Institutional Class.
(2) Note that the Total Annual Fund Operating Expenses shown in the table above differ from the ratio of expenses
to average net assets included in the Equity Premium Income Fund’s financial highlights section of the Prospectus. The financial
highlights reflect operating expenses and include expense reductions from securities lending but exclude indirect expenses. The ratio
of expenses to average net assets in the financial highlights also includes interest expense incurred during the 2024 fiscal year.
Example. This Example is intended to help you
compare the cost of investing in the Equity Premium Income Fund with the cost of investing in other mutual funds. The Example assumes
that you invest $10,000 in the Equity Premium Income Fund for the time periods indicated and then redeem all of your shares at the end
of those periods. The Example also assumes that your investment has a 5% return each year and that the Equity Premium Income Fund’s
operating expenses remain the same. Although your actual costs may be higher or lower, based upon these assumptions your costs would be:
1 Year
3 Years
5 Years
10 Years
Advisor Class
$126
$393
$681
$1,500
Institutional Class
$101
$315
$547
$1,213
Investor Class
$111
$347
$601
$1,329
Calendar Year Return as of December 31
Investor Class
During the period shown in the bar chart, the best
performance for a quarter was 14.0