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July 17, 2017 | ATLANTA CHICAGO DENVER FAYETTEVILLE IRVINE KANSAS CITY LITTLE ROCK LOS ANGELES MINNEAPOLIS OKLAHOMA CITY PHILADELPHIA RICHMOND SCOTTSDALE WASHINGTON WICHITA |
DALE DIXON
Dale.dixon@kutakrock.com
(402) 346-6000
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C.20549-0306
Attention: Ms. Katherine Hsu
| Re: | Cabela’s Credit Card Master Note Trust |
Form10-K for Fiscal Year Ended December 31, 2016
Filed March 29, 2017
File Nos.333-192577-02
Ladies and Gentlemen:
On behalf of World’s Foremost Bank (“WFB”), we are responding to the Staff’s oral comment of July 11, 2017 regarding our response on behalf of WFB Funding, LLC (the “Registrant”) and WFB on June 10, 2017 to the Staff’s letter to Mr. Sean B. Baker, dated June 27, 2017, regarding the Registrant’s Form10-K for the Fiscal Year Ended December 31, 2016 (the “Form10-K”), as filed on March 29, 2017. Capitalized terms used herein have the same meanings as in the Form10-K unless otherwise noted.
Oral Comment
| 1. | We note your response. While we acknowledge your statement that the servicing assessment was made under Item 1122(d)(4), we believe that Item 1122(d)(1)(v) continues to be applicable to your servicing assessment under the circumstances you set forth in your letter, given your aggregation of the information and conveyance of payment information to U.S. Bank in order for U.S. Bank to make payments. Please confirm in future filings you will assess your accurate conveyance of information to U.S. Bank under Item 1122(d)(1)(v). |
Response:
WFB confirms that it will assess its accurate conveyance of information to U.S. Bank under Item 1122(d)(1)(v) in any future reports on assessment delivered by WFB.
KUTAK ROCK LLP
Securities and Exchange Commission
July 17, 2017
Page 2
Please feel free to contact me at(402) 231-8732 or dale.dixon@kutakrock.com if you need anything further in connection with this matter.
Sincerely,
/s/ H. Dale Dixon III
H. Dale Dixon III
