Frontier Fund Management LLC
March 19, 2018
VIA E-MAIL AND EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
Attn: Mr. Robert F. Telewicz Jr.
| Re: | Frontier Funds Frontier Balanced Fund Frontier Diversified Fund Frontier Heritage Funds Frontier Long/Short Commodity Fund Frontier Masters Fund Frontier Select Fund Frontier Winton Fund Form 10-K Filed March 31, 2017 File No. 000-51274 |
Dear Mr. Telewicz:
Frontier Fund Management LLC, the managing owner (the “Managing Owner”) of Frontier Funds (formerly, Equinox Frontier Funds), a Delaware statutory trust (the “Trust”), organized in series (each of the above-referenced series of the Trust, a “Series” and collectively, the “Series”), hereby files, via EDGAR, its response to the comment letter of the Securities and Exchange Commission (the “Commission”), dated March 14, 2018, relating to the Trust’s and each Series’ Form 10-K filed on March 31, 2017 (File No. 000-51274). We have prepared our response with the assistance of our outside legal counsel. A copy of this letter has been sent to the Commission via electronic mail.
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations for the Twelve Months Ended December 31, 2016
Comment #1
We have considered your response to our prior comment. In the interests of transparency, we continue to believe your MD&A should include a summary and discussion of all direct and embedded fees, including but not limited to fees embedded in gains (losses) from trading companies and fees embedded in gains (losses) from swaps and other derivatives. Please revise your disclosure in future filings accordingly.
Securities and Exchange Commission
March 19, 2018
Page 2
Response #1
In future public filings of information required by Item 303 of Regulation S-K (Management’s Discussion and Analysis of Financial Condition and Results of Operations), the Trust and each Series will include a summary and discussion of direct and embedded fees, including, but not limited to, fees embedded in gains (losses) from trading companies and fees embedded in gains (losses) from swaps and other derivatives.
Securities and Exchange Commission
March 19, 2018
Page 3
If you have any further questions, comments or informational requests relating to this matter, please do not hesitate to contact me at (303) 454-5501, or our outside counsel, Timothy Selby of Alston & Bird LLP, at (212) 210-9494.
Sincerely,
/s/ Patrick F. Hart
Patrick F. Hart
Member of the Executive Committee
Cc: Timothy P. Selby, Alston & Bird LLP
Allison A. Muth, Alston & Bird LLP
