MH Elite Portfolio of Funds Trust
43 Highlander Drive
Scotch Plains NJ 07076
1-800-318-7969
January 31, 2017
Attn: Lauren Hamilton
Subject: Response to SEC comments made on January 5, 2017 with regards to a Sarbanes-Oxley financial review of MH Elite’s 12/31/2015 Annual Report.
1.
As per rules under Regulation S-X12-12, with respect to reporting the investment cost and aggregate unrealized appreciation and depreciation on investments for federal income tax purposes, future filings of Form N-Q will include cost basis of funds owned and amount of unrealized gain or loss.
Currently this information is reported in semi-annual and audited annual reports under Notes to Financial Statements, note 3.
2.
Schedule of Investments will better disclose the specific share class for each underlying fund. The term “Class” will be inserted as appropriate. For Example, Westwood Small Cap Value I will now be listed as Westwood Small Cap Value Class I and Vanguard Small Cap Value Index Adm will be reported as Vanguard Small Cap Value Index Adm Class.
3.
Fund policy for recording interest income as per Generally Accepted Accounting Principles (GAAP). Note 1, Organization and Significant Accounting Policies, of Annual and Semi-Annual Reports, will disclose the following under Investment Income: Interest income is recognized on an accrual basis when earned.
There are a number of underlying funds, particularly within MH Elite Income Fund of Funds, that pay a dividend or interest on a monthly basis. Dividends and interest are recorded and included in cash as earned. Money Market funds pay interest monthly. Exhibit A of this filing contains Posted Transaction Details from the custodian, Huntington National Bank. Transactions are first identified as dividends under transaction description. Distributions are also reported by tax code including a tax code description of either a dividend or interest. We record distributions as per tax code description and report on Statement of Operations accordingly.
4.
There are no fee waivers. According to the Administrative Services Agreement between MH Elite Portfolio of Funds Trust and the adviser, MH Investment Management Inc., the adviser has agreed to pay the expenses incurred for the conduct of business by the Funds. Any expenses incurred by the Funds that exceed the total annual fund operating expenses will be paid by the Adviser. Any expenses that exceed the total fund operating expenses paid by MH Elite Portfolio of Funds Trust cannot be recouped at a later date.
Sincerely,
/s/ Harvey Merson
Harvey Merson
President
MH Elite Portfolio of Funds Trust
43 Highlander Drive
Scotch Plains NJ 07076
1-800-318-7969
Exhibit A
MH Elite Portfolio of Funds Trust
43 Highlander Drive
Scotch Plains NJ 07076
1-800-318-7969
MH Elite Portfolio of Funds Trust
43 Highlander Drive
Scotch Plains NJ 07076
1-800-318-7969