DoubleLine Flexible Income Fund Class N (DLINX)
Filed: 22 Dec 16, 12:00am
 |
ROPES & GRAY LLP
2099 PENNSYLVANIA AVENUE, NW
WASHINGTON, DC 20006-6807
WWW.ROPESGRAY.COM |
| Nathan D. Briggs | ||||||
| December 22, 2016 | T +1 (202) 626-3909 | |||||
F +1 (202) 383-9308 nathan.briggs@ropesgray.com |
VIA EDGAR
Division of Investment Management
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549
Attn: Anu Dubey
| Re: | DoubleLine Funds Trust (the “Trust”), with respect to DoubleLine Shiller Enhanced |
International CAPE® (the “Fund”), File Nos. 811-22378 and 333-164298
Dear Ms. Dubey:
This letter is being filed to respond to the comment received from you on December 21, 2016, regarding the Trust’s Post-Effective Amendment (“PEA”) No. 52 to its registration statement. PEA No. 52 was filed pursuant to Rule 485(a) under the Securities Act of 1933, as amended, on Form N-1A on September 2, 2016 to register Class I and Class N shares of the Fund, a new series of the Trust. A summary of the Staff’s comment and the Trust’s response thereto, are set forth below.
| 1. | Comment: Please advise the Staff how the Fund, the name of which we understand is being changed to DoubleLine Shiller Enhanced International CAPE®, meets the standards set forth in footnote 42 to the adopting release for Rule 35d-1 under the Investment Company Act of 1940, stating, in relevant part, “[t]he terms ‘international’ and ‘global,’ however, connote diversification among investments in a number of different countries throughout the world, and ‘international’ and ‘global’ funds will not be subject to the [80%] rule. We would expect, however, that investment companies using [this term] in their names will invest their assets in investments that are tied economically to a number of countries throughout the world.”SeeInvestment Company Names, Investment Company Act Release No. IC-24828 (Jan. 17, 2001). |
| Response: The Fund has added the following disclosure to its principal investment strategies in connection with its name change (new disclosure in italics): |
| The Fund will seek to use derivatives, or a combination of derivatives and direct investments, to provide a return that tracks closely the performance of the Shiller Barclays CAPE® Europe Sector Net TR NoC USD Index (the “Index”).The Fund, through its investment exposure to the Index, will have exposure to investments tied economically to a number of countries throughout the world. The Index is currently composed of issuers in fifteen different countries, generally in Europe. |
The Fund believes that the new disclosure noted above illustrates how it will invest its assets in investments that are tied economically to a number of countries throughout the world in accordance with the Staff’s position noted in this Comment.
* * * * *
We believe that this submission fully responds to your comment. Please feel free to call me at (202) 626-3909 if you have any questions regarding the foregoing.
Very truly yours,
/s/ Nathan D. Briggs
Nathan D. Briggs
| cc: | Mr. Ronald R. Redell |
Timothy W. Diggins, Esq.
Jeremy C. Smith, Esq.