(212) 318-6736
ryanjonson@paulhastings.com
March 9, 2022
Mr. Jeffrey W. Long
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
Re:
Keeley Funds, Inc. (the “Trust”)
File Numbers: 333-124430; 811-21761
Dear Mr. Ellington:
This letter responds to oral comments provided by you to the undersigned with respect to the certified shareholder reports on Form N-1A for the Trust, filed on January 29, 2021 SEC Accession No. 0001387131-21-001421 (the “Registration Statement”).
The Trust’s responses to your comments are reflected below. We have restated your comments for ease of reference. Capitalized terms shall have the same meaning as in the Certified Shareholder Reports, unless otherwise indicated.
Comment 1: Please explain how shareholder concentration risk is addressed in the summary and statutory prospectus of the Registration Statement. If the shareholder concentration risk is not addressed, then please include it in future filings if appropriate.
Response: The Trust respectfully confirms that it will make this change in all future filings as appropriate.
/s/ Ryan Johnson
Ryan Johnson
cc:
Michael R. Rosella
Vadim Avdeychik
John C. Ball
Peter Goldstein