THOMPSON | ATLANTA CINCINNATI COLUMBUS NEW YORK |
HINE | BRUSSELS CLEVELAND DAYTON WASHINGTON, D.C. |
March 13, 2008
Chad Eskildsen
Senior Accountant
Office of Disclosure and Review
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 2-0549
RE: Presidio Funds; File Nos. 333-122412 and 811-21707
Dear Mr. Eskildsen:
On March 4, 2008, you provided comments on an annual report filed on Form N-CSR by Presidio Funds (the “Registrant”) on July 3, 2007. Please find below the Registrant's responses to your comments. For your convenience, I have summarized your comments.
1.
Comment. On the Statement of Assets and Liabilities, "Net Assets" and "Net Assets, for 4,328,177 Shares Outstanding" do not reconcile. Please explain.
Response. The entry for "Paid in Capital" is incorrect. The correct number is $52,077,163, rather than $52,044,163. When the correct number is added to the other components of the Registrant's nets assets, both "Net Assets" and "Net Assets, for 4,328,177 Shares Outstanding" total $63,696,288.
1.
Comment. The Statement of Operations show net investment losses of $221,810. Note 2 to the Registrant's financial statements discloses that "[i]n accordance with SOP - 93-2, the Fund has recorded a reclassification in the capital account. As of April 30, 2007, the Fund has recorded a permanent book/tax difference of $142,131 from net investment loss to paid-in-capital." Please explain why only $142,131 of net investment losses was reclassified.
Response. The reclassification of the $142,131 does not equal the net investment loss of $221,810 because for tax purposes the Registrant was able to use net short-term gains to reduce the loss.
2.
Comment. Please provide a capital account rollforward for the period April 30, 2006 through April 30, 2007.
Response. A copy of the Registrant's capital account rollforward is attached to this letter.
Michael.Wible@ThompsonHine.com Phone 614.469.3297 Fax 614.469.3361 | df 572916.1 |
Chad Eskildsen
March 13, 2008
Page 2
The Registrant has authorized me to convey to you that the Registrant acknowledges the following:
1.
The Registrant is responsible for the adequacy and accuracy of the disclosure in the filings reviewed by the staff;
2.
Staff comments or changes to disclosure in response to staff comments in a filing reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and
3.
The Registrant may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
______________________________________
If you have any questions or additional comments, please call the undersigned at 614-469-3297.
Best regards,
/s/ Michael V. Wible
Michael V. Wible
Enclosure
cc:
Kevin O'Boyle
Jeffrey Provence
Michael Baranowsky
Michael.Wible@ThompsonHine.com Phone 614.469.3297 Fax 614.469.3361 | df 572916.1 |
