Lord Abbett Us Gov & Gov Sponsored Enterpr Money Market Fund
Filed: 13 Jan 10, 12:00am
LORD ABBETT U.S. GOVERNMENT & GOVERNMENT SPONSORED
ENTERPRISES MONEY MARKET FUND, INC.
90 Hudson Street
Jersey City, NJ 07302
January 12, 2010
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549
| Re: | Lord Abbett U.S. Government & Government Sponsored Enterprises Money Market Fund, Inc.; 1933 Act File No. 002-64536; 1940 Act File No. 811-02924 (the “Fund”) |
Ladies and Gentlemen:
Reference is made to the Semi-Annual Reports for Registered Investment Companies on Form N-SAR filed by the Fund with the U.S. Securities and Exchange Commission (the “Commission”) via EDGAR on the following dates: August 31, 2009; February 27, 2009; August 29, 2008; and February 29, 2008 (the “Money Market N-SARs”).
This letter responds to a telephonic request from the Commission staff requesting information regarding Item 74W of the Money Market N-SARs. Item 74W requires the Fund to report the mark-to-market net asset value per share (to four decimals) based upon the semi-annual or annual financial statements as of the same date contained in shareholder reports corresponding to the Money Market N-SARs.
Item 74W of each of the Money Market N-SARs each reflected the following response: $1.0000. Upon further review, the Fund determined that the amounts provided in response to Item 74W for the Money Market N-SARs filed on August 31, 2009 and February 27, 2009 were incorrect. The correct response for Item 74W for each of the Money Market N-SARs are as follows:
Date of Filing | Accession Number | Correct Response to Item 74W | ||
August 31, 2009 | 0001171520-09-000592 | 1.0001 | ||
February 27, 2009 | 0001171520-09-000134 | 1.0007 | ||
August 29, 2008 | 0001171520-08-000513 | 1.0000 | ||
February 29, 2008 | 0001171520-08-000125 | 1.0000 |
In accordance with the request of the Commission staff, the Fund is contemporaneously filing amendments to the Money Market N-SARs, including: (i) the Money Market N-SARs filed
Securities and Exchange Commission
January 12, 2010
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on August 31, 2009 and February 27, 2009, for which the correct response to Item 74W is provided; and (ii) the Money Market N-SARs filed on August 29, 2008 and February 29, 2008 for which there is no change to the response for Item 74W. In addition, the Fund has instituted corrective measures that are reasonably designed to ensure that the Fund’s responses to Item 74W in its future filings will reflect the correct data.
* * * * *
The Fund acknowledges in connection with this filing the following: (i) it is responsible for the adequacy and accuracy of the disclosure in the Semi-Annual Reports on Form N-SAR (“N-SARs”); (ii) Commission staff comments or changes to the disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the N-SARs; and (iii) it 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, please call the undersigned at (201) 827-2225.
Sincerely,
/s/ Thomas R. Phillips
Thomas R. Phillips
Vice President and Assistant Secretary