January 14, 2005
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
RE: Renaissance Capital Greenwich Funds [“Trust”] – The IPO Plus Aftermarket Fund [“Fund”][File Nos. 333-21311, 811-8049)
Dear Sir/Madam:
This letter addresses your comments respecting the Trust’s 2004 Annual Report:
1. Comment(s) respecting the Statement of Assets and Liabilities
(a)
Omission of redemption fee information
A footnote informing the reader/shareholder of the Fund’s 2% redemption fee will be added to the next semi-annual report and all future reporting. The footnote will be placed immediately after the “Net Asset Value” disclosure and will read as follows:
The Fund imposes 2% redemption fee on shares, other than those from the reinvestment of dividends and capital gains, sold that were held 90 days or fewer.
2. Comment(s) respecting the Statement of Operations
(a)
Disclosure of interest/dividend expenses from short sale activity
No interest/dividend expense resulted from short sale activity during the period covered by this annual report.
The next semi-annual report and all future reporting will include interest/dividend expense amounts within the Statement of Operations should such expenses be incurred during the reporting period.
3.Comment(s) respecting the Notes to Financials
(a)
Identification of Fair-Valued Securities
There were no securities for which market quotations were not readily available as of the Fund’s fiscal year-end.
The next semi-annual report and all future reporting will include detail of any and all Fair-Valued securities should such securities be held by the Fund. In the event no securities are Fair-Valued, a notation reflecting as much will be added to the existing language.
(b)
Factors considered by the Board of Trustees in Fair-Valuing Securities
The next semi-annual report and all future reporting will include a general discussion of the factors considered by the Board in determining the Fair-Value for a security. The disclosure will be as follows: “Any securities or other assets for which market quotations are not readily available are valued at fair value as determined in accordance with the Trust’s “Procedures for Valuing Illiquid Securities and Securities for which Market Quotations are Not Readily Available or May be Unreliable (the “Procedures”).” The Procedures consider, among others, the following factors to determine a security’s fair value: market prices for the security or securities deemed comparable; dealer valuations of the security or securities deemed comparable; and determinations of value by one or more pricing services for the security or securities deemed comparable.”
4. Comment(s) respecting Expense Disclosure Note
(a)
Ongoing vs. Transaction Costs
The next semi-annual report and all future reporting will include a discussion of transaction costs associated with an investment in the Fund. The example, however, will exclude the effects of transaction costs such as sales charges and Contingent Deferred Sales Charges [“CDSCs”] as the Fund does not impose either sales charges or CDSCs. The example will also exclude redemption fees and the existing language will be amended to reflect as much.
5. Comment(s) respecting Item 4 (e) 2 from Form N-CSR
(a)
Percentage disclosed in Item
Item 4(e)(2) of Form N-CSR will be completed in the manner prescribed by the instructions thereto for all future filings. With respect to tot the Trust’s 2004 annual report, this response should have been 0%.
6. Comment(s) respecting the filing of Form NT-NSAR and the filing of Form N-SAR (b)
Form NT-NSAR was filed on November 29, 2004. Form N-SAR (b) was filed on December 13, 2004. It is our understanding that an extension was filed as our service provider needed additional time to convert required data and ensure its accuracy from the previous service provider, whose services ceased on January 31, 2004. We will ensure that future N-SAR (a) and (b) filings are made within 60 days of the relevant fiscal period end for the Fund.
Please call me at (203) 622-2978 if you have any questions respecting the foregoing responses.
Sincerely,
/s/ Kathleen S. Smith
Kathleen S. Smith
Vice President, Treasurer
Renaissance Capital Greenwich Funds
