October 12, 2010
Ms. Valerie Lithotomos
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: | Pre-Effective Amendment No. 4 to Form N-14 for Calvert Impact Fund, Inc. (File No. 333-169082) |
Dear Ms. Lithotomos:
The above Registrant filed today electronically, Pre-effective Amendment #4 to the Form N-14 for the Calvert Small Cap Value Fund, a series of Calvert Impact Fund, Inc., for the proposed merger of the Calvert New Vision Small Cap Fund, a series of The Calvert Fund, into the Calvert Small Cap Fund (formerly the Calvert Small Cap Value Fund), pursuant to Rule 14a-6 of the Securities and Exchange Act of 1934.
This amendment reflects those comments made to the filing (Prospectus/Proxy Statement) pursuant to our conversation day with the Staff's accountant, as detailed below:
- Added the following disclosure to clarify the Expense Table: Management fees include the advisory fee of 0.75% for all classes and the administrative fee of 0.25% for Class A, B and C shares and 0.10% for Class I shares. The advisory fee for the Combined Fund has been reduced by 0.05% for all classes.
- Added the following disclosure regarding economies of scale: It is possible that the Advisor will benefit from the economies of scale in the combined Calvert Small Cap Fund because the amount of the fee waiver will be reduced.
- File an Amended Schedule to the Investment Advisory Agreement for the Calvert Small Cap Fund as an exhibit to the Part C, which reflects the waiver of 5 basis points from the advisory fee.
- Revised pro forma financials as requested in the Part B; except please note that the pro forma financial information remains for the period ending March 31, 2010 to tie into the semi-annual period.
Lastly, as discussed during our conversation, I can confirm that the rationale for selecting the Calvert Small Cap Fund as the accounting survivor was based on an assessment of the expenses.
I respectfully request that the filing be declared effective today, October 12, 2010.
Should you have any questions, please contact me at 301-951-4858.
Very truly yours,
/s/ Ivy Wafford Duke
Ivy Wafford Duke
Assistant Vice President and
Deputy General Counsel