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Correspondence 0000051931-23-000613 from Capital Group Dividend Growers ETF (CIK 0001969489)

Capital Group Dividend Growers ETF (CIK 0001969489)
Date: July 24, 2023 · CIK: 0001969489 · Accession: 0000051931-23-000613

AI Filing Summary & Sentiment

File numbers found in text: 333-271210, 333-271211, 333-271212, 811-23865, 811-23866, 811-23867

Date
July 24, 2023
Author
Not clearly detected
Form
CORRESP
Company
Capital Group Dividend Growers ETF (CIK 0001969489)

Letter

Division of Investment Management File Nos. 333-271210 and 811-23866 Capital Group Core Balanced ETF (“Core Balanced Fund”) Initial Registration Statement on Form N-1A File Nos. 333-271211 and 811-23867

Dear Mr. Cowan:

In response to your comments, received on May 10, 2023, to the initial registration statements on Form N-1A (the “Registration Statements”) of International Equity Fund, Dividend Growers Fund and Core Balanced Fund (each, a “Fund” and together, the “Funds”), we hereby file Pre-Effective Amendment No. 1 to the Registration Statements under the Investment Company Act of 1940 (the “1940 Act”) (such amendment, the “Amendment”) pursuant to Rule 472 of the 1933 Act. Our responses to your comments are set forth below.

All funds

1. We note that the registration statements are missing information and exhibits and contain bracketed disclosures. We may have comments on such portions when you complete them in a pre-effective amendment, on disclosures made in response to this letter, on information supplied supplementally, or on exhibits filed in any pre-effective amendment. Please plan accordingly.

Response: We have addressed this comment in the Amendment and acknowledge that you may have additional comments.

2. Please advise us if you have submitted or expect to submit any exemptive applications or no-action requests in connection with the registration statements.

Response: The funds do not presently intend to rely on any exemptive relief. However, as disclosed in each Registration Statement: “While it has no present intention of doing so, the fund’s board could determine that it is in the best interests of the fund not to publicly disclose the fund’s complete portfolio holdings on a daily basis. In such event, and upon prior written notice to shareholders, the fund will be required to rely on exemptive relief granted by the SEC, or rule or regulation in force at such time, to disclose its full portfolio holdings on a quarterly basis, similar to mutual funds.” We confirm supplementally that an application was filed on April 30, 2021, and amended on August 25, 2021, for an order under Section 6(c) of the 1940 Act for an exemption from Sections 2(a)(32), 5(a)(1), 22(d) and 22(e) of the 1940 Act and Rule 22c-1 under the 1940 Act, and under Sections 6(c) and 17(b) of the 1940 Act for an exemption from Sections 17(a)(1) and 17(a)(2) of the 1940 Act, and under Section 12(d)(1)(J) of the 1940 Act for an exemption from Sections 12(d)(1)(A) and 12(d)(1)(B) of the 1940 Act. If and when granted, such relief would allow the Funds flexibility to convert to a less transparent fund structure (in each case subject to board approval and prior written notice to shareholders), which would allow the Funds to disclose their portfolio holdings on a quarterly rather than daily basis.

3. Please include the ticker symbols in EDGAR. See Regulation S-T, Rule 313(b)(1).

Response: We confirm that the ticker symbols for the funds have been added in EDGAR.

4. Where a comment is made with regard to disclosure in one location of a registration statement, it is applicable to all similar disclosure appearing elsewhere in that registration statement.

Response: We acknowledge this comment.

5. Please note that for ease of reference we refer to the requirements of Items 1-8 as the “Summary Prospectus” and Items 9-13 as the “Statutory Prospectus.”

Response: We acknowledge this comment.

All funds (unless otherwise specified)

Summary prospectus

Fees and expenses of the fund

6. The prospectus indicates that the fund may invest in the Central Funds, as well as one or more fixed income ETFs in the case of the Core Balanced Fund. If acquired fund fees and expenses (“AFFEs”) from such investments will exceed 0.01% of the average net assets of the fund, please disclose these fees and expenses as a separate line item in the fee table. Further, if included as a separate line item, please also disclose in a footnote to the fee table that AFFEs are based on estimated amounts for the current fiscal year. Otherwise, please confirm supplementally that such expenses, if any, are reflected in “Other Expenses.” See Instr. 3(f)(i) to Item 3.

Response: We confirm supplementally with respect to International Equity Fund and Dividend Growers Fund that, if acquired fund fees and expenses (AFFE) exceed 0.01% of the average net assets of the fund, the fund will include a separate line item in the fee table for AFFE. Neither fund’s AFFE is expected to exceed 0.01% of the average net assets of the fund at this time, and as a result, any such expenses will be reflected in "Other Expenses."

As noted, Core Balanced Fund will invest in one or more fixed-income ETFs. To the extent such underlying ETFs are advised or managed by the fund’s investment adviser or its affiliate, the acquired fund fees and expenses attributable to such investments by Core Balanced Fund will be paid by the adviser in accordance with the terms of the Investment Advisory and Service Agreement between the adviser and Core Balanced Fund. Accordingly, such acquired fund fees and expenses will not be disclosed as a fund expense. To that end, please see our response to Comment 23 below. We will also amend our disclosure in Item 10 as follows:

“As compensation for these services, Capital Research and Management Company is entitled to receive a management fee from the fund of [.xx]% of the fund’s average daily net assets. Please see the statement of additional information for further details. A discussion regarding the basis for approval of the fund’s Investment Advisory and Service Agreement by the fund’s board of trustees will be contained in the fund’s annual report to shareholders for the fiscal year ending December 31, 2023. Pursuant to such agreement, Capital Research and Management Company will pay for certain operating expenses of the fund, including acquired fund fees and expenses where the acquired fund is managed or advised by Capital Research and Management Company or its affiliates. Please see the statement of additional information for further details.”

In addition, we confirm that the fund is not expected at this time to have any AFFE attributable to underlying fixed-income ETFs that are not advised or managed by the fund’s investment adviser or its affiliate. To the extent such AFFE is expected to exceed 0.01% of the average net assets of the fund, we confirm that any such expenses will be reflected in a separate line item in the fee table for AFFE.

Principal investment strategies

7. Please identify the “other equity-type securities” (International Equity Fund and Dividend Growers Fund) and “other equity securities” (Core Balanced Fund) in which the funds will principally invest or count towards the applicable fund’s names test and disclose any associated risks.

If “other equity-type securities” or “other equity securities” include convertible securities, as indicated in the risk factor titled Investing in growth-oriented stocks, and the fund expects to invest in contingent convertible securities (“CoCos”), the fund should consider what, if any, disclosure is appropriate. The type and location of disclosure will depend on, among other things, the extent to which the fund invests in CoCos, and the characteristics of the CoCos, (e.g., the credit quality, the conversion triggers). If CoCos are or will be a principal type of investment, the fund should provide a description of them and should provide appropriate risk disclosure. Please identify the “other equity-type securities” (International Equity Fund and Dividend Growers Fund) and “other equity securities” (Core Balanced Fund) in which the funds will principally invest or count towards the applicable fund’s names test and disclose any associated risks.

Response: For each of the three funds, we will update the disclosure to provide in Item 4 that the fund will invest at least 80% of its assets in “equity securities,” and further in Item 9 that such equity securities will include “common stocks and other equity-type securities such as preferred stocks, convertible preferred stocks and convertible bonds.” Because preferred stocks, convertible preferred stocks and convertible bonds are not expected to be a principal investment of any fund, we believe it would be misleading to specify them in the summary prospectus. These securities are referenced in the risk factor titled “Investing in growth-oriented stocks” because growth-oriented investments may include investments in these types of securities.

We confirm with respect to each fund that contingent convertible securities (“CoCos”) are not expected to be a principal investment. As a result, in keeping with the Staff’s guidance on layered disclosure, the risks of investing in CoCos are described in more detail in the SAI of the funds. If any of the funds begins to invest in convertible securities or CoCos as a principal investment strategy, then we confirm that they will be disclosed as such in the Principal investment strategies section of the prospectus.

8. To aid investor understanding, please briefly describe the multi-manager approach used by the investment adviser to the fund in this section, rather than cross-referencing to another section of the prospectus.

Response: We will delete the cross-reference to Item 10 of Form N-1A in response to this comment.

International Equity Fund

9. Please disclose the criteria used to determine common stocks that “the investment adviser believes have the potential for growth, many of which have the potential to pay dividends.”

Response: The existing disclosure in Item 4 below describes the criteria used by the investment adviser to identify investments for the fund. In response to this comment, we will update the disclosure in Item 9 as follows:

"In pursuing the fund’s objective, the fund’s investment adviser focuses primarily on companies with attributes that are associated with long-term growth and resilience to market declines, such as those with strong company management, participation in a growing market, strong balance sheets, payment of dividends and the potential for above average growth in earnings, revenues, book value, cash flow and/or return on assets. The adviser considers several relevant attributes and no single attribute is necessarily determinative to an investment decision."

10. Please expressly disclose how the adviser determines that an issuer is “outside the United States.”

Response: We will add the following disclosure in Items 4 and 9 to address this comment:

Item 4: “In determining the domicile of an issuer, the fund’s investment adviser will generally look to the determination of a leading provider of global indexes, such as MSCI Inc. (MSCI).”

Item 9: In determining the domicile of an issuer, the fund’s investment adviser will generally look to the determination of a leading provider of global indexes, such as MSCI Inc. (MSCI). However, in certain limited circumstances (including where relevant data is unavailable or the nature of the holding warrants special considerations), the adviser may also take into account additional factors, such as where the issuer’s securities are listed, and where the issuer is legally organized, maintains principal corporate offices, conducts its principal operations, generates revenues and/or has credit risk exposure.”

In keeping with the Staff's guidance on layered disclosures, International Equity Fund's Statement of Additional Information will be supplemented as follows to further describe how the investment adviser of the fund determines the domicile of an issuer, whether in or outside the United States:

"For purposes of determining whether an investment is made in a particular country or geographic region, the fund’s investment adviser will generally look to the domicile of the issuer in the case of equity securities, and to the country to which the security is tied economically in the case of debt securities. In doing so determining the domicile of an issuer, the fund’s investment adviser will generally look to the domicile determination of a leading provider of global indexes, such as Morgan Stanley Capital InternationalMSCI Inc. (MSCI) for equity securities and Bloomberg for debt securities. However, the adviser in its discretion In certain limited circumstances (including where relevant data is unavailable or the nature of a holding warrants special considerations), the adviser also may also take into account such additional factors, as applicable, including where the issuer’s securities are listed; and, where the issuer is legally organized, maintains principal corporate offices, conducts its principal operations, and generates revenues and/or has credit risk exposure; and the source of guarantees (if any) of such securities."

Dividend Growers Fund

11. Please expressly disclose how the adviser determines that an issuer is “outside the United States.” Please also disclose how the fund will “invest [its] assets in investments that are tied economically to a number of countries throughout the world.” See Investment Company Names, Investment Company Act Release No. 24828, at n. 42 (Jan. 17, 2001). For example, the fund could include a policy that, under normal market conditions, it will invest significantly (e.g., at least 40% of its assets, unless market conditions are not deemed favorable, in which case the fund would invest at least 30% of its assets) in companies organized or located in multiple countries outside the United States or doing a substantial amount of business in multiple countries outside the United States.

Response: In response to this comment, we have removed the reference to “World” in the fund’s name. That said, it will be a principal investment strategy of the fund to invest in assets that are tied economically to a number of countries throughout the world and, accordingly, the “Principal investment strategies” section will retain disclosure regarding such focus. In addition, please see the response to Item 10 above. We will make the same changes to the prospectus and SAI disclosure for this fund as relates to the investment adviser's country determinations.

12. Please briefly disclose in the summary and in more detail in response to item 9, the criteria used by the investment adviser to select common stocks of companies with respect to their “potential to provide combinations of current yield and dividend growth over the long term.”

Response: We will add to the summary as follows to address this comment:

“The fund invests primarily in common stocks of companies around the world that the investment adviser believes have the potential to provide combinations of current yield and dividend growth over the long-term. In selecting investments, the adviser evaluates a company's current dividend yield, its dividend history and forecast of dividend growth based on the company's overall financial health.”

In addition, we will update the existing disclosure in the statutory prospectus as follows:

“The fund invests primarily in common stocks of companies around the world that the investment adviser believes have the potential to provide combinations of current yield and dividend growth over the long-term. In making this determination, the

Show Raw Text
CORRESP
1
filename1.htm

    Clara Kang

    Associate Counsel

    Capital Research and Management Company

    333 South Hope Street

    Los Angeles, California 90071-1406

    (213) 615-3736

July 24, 2023

Mark A. Cowan

Senior Counsel

U.S. Securities and Exchange Commission

Division of Investment Management

Disclosure Review Office

100 F Street, N.E.

Washington, D.C. 20549-3628

Re:	      Capital Group International Equity ETF (“International
Equity Fund”)

Initial Registration Statement on Form N-1A

File Nos. 333-271212 and 811-23865

Capital Group Dividend Growers ETF (formerly, Capital Group World
Dividend Growers ETF) (“Dividend Growers Fund”)

Initial Registration Statement on Form N-1A

File Nos. 333-271210 and 811-23866

Capital Group Core Balanced ETF (“Core
Balanced Fund”)

Initial Registration Statement on Form N-1A

File Nos. 333-271211 and 811-23867

Dear Mr. Cowan:

In response to your comments, received on May 10, 2023,
to the initial registration statements on Form N-1A (the “Registration Statements”) of International Equity Fund, Dividend
Growers Fund and Core Balanced Fund (each, a “Fund” and together, the “Funds”), we hereby file Pre-Effective Amendment
No. 1 to the Registration Statements under the Investment Company Act of 1940 (the “1940 Act”) (such amendment, the “Amendment”)
pursuant to Rule 472 of the 1933 Act. Our responses to your comments are set forth below.

All funds

 1. We note that the registration statements are missing information and exhibits and contain bracketed disclosures.
We may have comments on such portions when you complete them in a pre-effective amendment, on disclosures made in response to this letter,
on information supplied supplementally, or on exhibits filed in any pre-effective amendment. Please plan accordingly.

Response: We have addressed this
comment in the Amendment and acknowledge that you may have additional comments.

 2. Please advise us if you have submitted or expect to submit any exemptive applications or no-action requests
in connection with the registration statements.

Response: The funds do not presently
intend to rely on any exemptive relief. However, as disclosed in each Registration Statement: “While it has no present intention
of doing so, the fund’s board could determine that it is in the best interests of the fund not to publicly disclose the fund’s
complete portfolio holdings on a daily basis. In such event, and upon prior written notice to shareholders, the fund will be required
to rely on exemptive relief granted by the SEC, or rule or regulation in force at such time, to disclose its full portfolio holdings on
a quarterly basis, similar to mutual funds.” We confirm supplementally that an application was filed on April 30, 2021, and amended
on August 25, 2021, for an order under Section 6(c) of the 1940 Act for an exemption from Sections 2(a)(32), 5(a)(1), 22(d) and 22(e)
of the 1940 Act and Rule 22c-1 under the 1940 Act, and under Sections 6(c) and 17(b) of the 1940 Act for an exemption from Sections 17(a)(1)
and 17(a)(2) of the 1940 Act, and under Section 12(d)(1)(J) of the 1940 Act for an exemption from Sections 12(d)(1)(A) and 12(d)(1)(B)
of the 1940 Act. If and when granted, such relief would allow the Funds flexibility to convert to a less transparent fund structure (in
each case subject to board approval and prior written notice to shareholders), which would allow the Funds to disclose their portfolio
holdings on a quarterly rather than daily basis.

 3. Please include the ticker symbols in EDGAR. See Regulation S-T, Rule 313(b)(1).

Response: We confirm that the ticker
symbols for the funds have been added in EDGAR.

 4. Where a comment is made with regard to disclosure in one location of a registration statement, it is applicable
to all similar disclosure appearing elsewhere in that registration statement.

Response: We acknowledge this comment.

 5. Please note that for ease of reference we refer to the requirements of Items 1-8 as the “Summary
Prospectus” and Items 9-13 as the “Statutory Prospectus.”

Response: We acknowledge
this comment.

All funds (unless otherwise specified)

Summary prospectus

Fees and expenses of the fund

 6. The prospectus indicates that the fund may invest in the Central Funds, as well as one or more fixed income
ETFs in the case of the Core Balanced Fund. If acquired fund fees and expenses (“AFFEs”) from such investments will exceed
0.01% of the average net assets of the fund, please disclose these fees and expenses as a separate line item in the fee table. Further,
if included as a separate line item, please also disclose in a footnote to the fee table that AFFEs are based on estimated amounts for
the current fiscal year. Otherwise, please confirm supplementally that such expenses, if any, are reflected in “Other Expenses.”
See Instr. 3(f)(i) to Item 3.

Response: We confirm supplementally
with respect to International Equity Fund and Dividend Growers Fund that, if acquired fund fees and expenses (AFFE) exceed 0.01% of the
average net assets of the fund, the fund will include a separate line item in the fee table for AFFE. Neither fund’s AFFE is expected
to exceed 0.01% of the average net assets of the fund at this time, and as a result, any such expenses will be reflected in "Other
Expenses."

As noted, Core Balanced Fund will
invest in one or more fixed-income ETFs. To the extent such underlying ETFs are advised or managed by the fund’s investment
adviser or its affiliate, the acquired fund fees and expenses attributable to such investments by Core Balanced Fund will be paid by
the adviser in accordance with the terms of the Investment Advisory and Service Agreement between the adviser and Core Balanced
Fund. Accordingly, such acquired fund fees and expenses will not be disclosed as a fund expense. To that end, please see our
response to Comment 23 below. We will also amend our disclosure in Item 10 as follows:

“As compensation for these services,
Capital Research and Management Company is entitled to receive a management fee from the fund of [.xx]% of the fund’s average daily
net assets. Please see the statement of additional information for further details. A discussion regarding the basis for approval of the
fund’s Investment Advisory and Service Agreement by the fund’s board of trustees will be contained in the fund’s annual
report to shareholders for the fiscal year ending December 31, 2023. Pursuant to such agreement, Capital
Research and Management Company will pay for certain operating expenses of the fund, including acquired fund fees and expenses where the
acquired fund is managed or advised by Capital Research and Management Company or its affiliates. Please see the statement of additional
information for further details.”

In addition, we confirm that the fund is
not expected at this time to have any AFFE attributable to underlying fixed-income ETFs that are not advised or managed by the
fund’s investment adviser or its affiliate. To the extent such AFFE is expected to exceed 0.01% of the average net assets of the
fund, we confirm that any such expenses will be reflected in a separate line item in the fee table for AFFE.

Principal investment strategies

 7. Please identify the “other equity-type securities” (International Equity Fund and Dividend
Growers Fund) and “other equity securities” (Core Balanced Fund) in which the funds will principally invest or count towards
the applicable fund’s names test and disclose any associated risks.

If “other equity-type securities”
or “other equity securities” include convertible securities, as indicated in the risk factor titled Investing in growth-oriented
stocks, and the fund expects to invest in contingent convertible securities (“CoCos”), the fund should consider what, if any,
disclosure is appropriate. The type and location of disclosure will depend on, among other things, the extent to which the fund invests
in CoCos, and the characteristics of the CoCos, (e.g., the credit quality, the conversion triggers). If CoCos are or will be a principal
type of investment, the fund should provide a description of them and should provide appropriate risk disclosure. Please identify the
“other equity-type securities” (International Equity Fund and Dividend Growers Fund) and “other equity securities”
(Core Balanced Fund) in which the funds will principally invest or count towards the applicable fund’s names test and disclose any
associated risks.

Response: For each of the three funds,
we will update the disclosure to provide in Item 4 that the fund will invest at least 80% of its assets in “equity securities,”
and further in Item 9 that such equity securities will include “common stocks and other equity-type securities such as preferred
stocks, convertible preferred stocks and convertible bonds.” Because preferred stocks, convertible preferred stocks and convertible
bonds are not expected to be a principal investment of any fund, we believe it would be misleading to specify them in the summary prospectus.
These securities are referenced in the risk factor titled “Investing in growth-oriented stocks” because growth-oriented investments
may include investments in these types of securities.

We confirm with respect to each fund
that contingent convertible securities (“CoCos”) are not expected to be a principal investment. As a result, in keeping
with the Staff’s guidance on layered disclosure, the risks of investing in CoCos are described in more detail in the SAI of
the funds. If any of the funds begins to invest in convertible securities or CoCos as a principal investment strategy, then we
confirm that they will be disclosed as such in the Principal investment strategies section of the prospectus.

 8. To aid investor understanding, please briefly describe the multi-manager approach used by the investment
adviser to the fund in this section, rather than cross-referencing to another section of the prospectus.

Response: We will delete the cross-reference
to Item 10 of Form N-1A in response to this comment.

International Equity Fund

 9. Please disclose the criteria used to determine common stocks that “the investment adviser believes
have the potential for growth, many of which have the potential to pay dividends.”

Response: The existing disclosure
in Item 4 below describes the criteria used by the investment adviser to identify investments for the fund. In response to this comment,
we will update the disclosure in Item 9 as follows:

"In pursuing the fund’s objective,
the fund’s investment adviser focuses primarily on companies with attributes that are associated with long-term growth and resilience
to market declines, such as those with strong company management, participation in a growing market, strong balance sheets, payment of
dividends and the potential for above average growth in earnings, revenues, book value, cash flow and/or return on assets. The
adviser considers several relevant attributes and no single attribute is necessarily determinative to an investment decision."

 10. Please expressly disclose how the adviser determines that an issuer is “outside the United States.”

Response: We will add the following
disclosure in Items 4 and 9 to address this comment:

Item 4: “In determining the domicile
of an issuer, the fund’s investment adviser will generally look to the determination of a leading provider of global indexes, such
as MSCI Inc. (MSCI).”

Item 9: In determining the domicile of an
issuer, the fund’s investment adviser will generally look to the determination of a leading provider of global indexes, such as
MSCI Inc. (MSCI). However, in certain limited circumstances (including where relevant data is unavailable or the nature of the holding
warrants special considerations), the adviser may also take into account additional factors, such as where the issuer’s securities
are listed, and where the issuer is legally organized, maintains principal corporate offices, conducts its principal operations, generates
revenues and/or has credit risk exposure.”

In keeping with the Staff's guidance on
layered disclosures, International Equity Fund's Statement of Additional Information will be supplemented as follows to further describe
how the investment adviser of the fund determines the domicile of an issuer, whether in or outside the United States:

"For
purposes of determining whether an investment is made in a particular country or geographic region, the fund’s investment
adviser will generally look to the domicile of the issuer in the case of equity securities, and to the country to which the security
is tied economically in the case of debt securities. In doing so determining
the domicile of an issuer, the fund’s investment adviser will generally look to the domicile determination
of a leading provider of global indexes, such as Morgan Stanley Capital
InternationalMSCI Inc. (MSCI) for equity securities and Bloomberg for debt
securities. However, the adviser in its discretion In
certain limited circumstances (including where relevant data is unavailable or the nature of a holding warrants special
considerations), the adviser also may also
take into account such additional factors, as
applicable, including where the issuer’s securities are listed; and,
where the issuer is legally organized, maintains principal corporate offices, conducts its principal operations, and
generates revenues and/or has credit risk exposure; and the source of guarantees (if any) of such
securities."

Dividend Growers Fund

 11. Please expressly disclose how the adviser determines that an issuer is “outside the United States.”
Please also disclose how the fund will “invest [its] assets in investments that are tied economically to a number of countries throughout
the world.” See Investment Company Names, Investment Company Act Release No. 24828, at n. 42 (Jan. 17, 2001). For example, the fund
could include a policy that, under normal market conditions, it will invest significantly (e.g., at least 40% of its assets, unless market
conditions are not deemed favorable, in which case the fund would invest at least 30% of its assets) in companies organized or located
in multiple countries outside the United States or doing a substantial amount of business in multiple countries outside the United States.

Response: In response to this comment,
we have removed the reference to “World” in the fund’s name. That said, it will be a principal investment strategy of
the fund to invest in assets that are tied economically to a number of countries throughout the world and, accordingly, the “Principal
investment strategies” section will retain disclosure regarding such focus. In addition, please see the response to Item 10 above.
We will make the same changes to the prospectus and SAI disclosure for this fund as relates to the investment adviser's country determinations.

 12. Please briefly disclose in the summary and in more detail in response to item 9, the criteria used by
the investment adviser to select common stocks of companies with respect to their “potential to provide combinations of current
yield and dividend growth over the long term.”

Response: We will add to the summary
as follows to address this comment:

“The fund invests primarily in common
stocks of companies around the world that the investment adviser believes have the potential to provide combinations of current yield
and dividend growth over the long-term. In selecting investments, the adviser evaluates a company's current
dividend yield, its dividend history and forecast of dividend growth based on the company's overall financial health.”

In addition, we will update the existing
disclosure in the statutory prospectus as follows:

“The fund invests primarily in common
stocks of companies around the world that the investment adviser believes have the potential to provide combinations of current yield
and dividend growth over the long-term. In making this determination, the