 October 18, 2016 | ATTORNEYS AT LAW 777 EAST WISCONSIN AVENUE, SUITE 3800 MILWAUKEE, WISCONSIN 53202-5306 414.271.2400 TEL 414.297.4900 FAX www.foley.com WRITER’S DIRECT LINE 414.297.5596 pfetzer@foley.com Email CLIENT/MATTER NUMBER 063723-0101 |
Via EDGAR System
Ms. Megan Miller U.S. Securities and Exchange Commission Division of Investment Management Washington, D.C. 20549 |
| Re: | OCM Mutual Fund (File No. 811-04010) |
Annual Report on Form N-CSR
Filed on February 1, 2016
Dear Ms. Miller:
On behalf of our client, OCM Mutual Fund, a Massachusetts business trust (Investment Company Act File No. 811-04010), which is comprised of one portfolio, the OCM Gold Fund (the “Fund”), set forth below are the Fund’s responses to oral comments of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), with respect to the above-referenced annual report of the Fund (the “Annual Report”). The numbered items set forth below express (in bold italics) the oral comments of the Staff, and following such comments are the Fund’s responses (in regular type).
Annual Report
1. In the “Organization” footnote to the financial statements, in future filings, please add in a reference to the fact that the Fund is a non-diversified fund.
Response: As requested, in future filings the Fund will add in a reference to the fact that the Fund is a non-diversified Fund.
2. We noted the “Subsequent Events” footnote to the financial statements saying that after November 30, 2015 there was a 30% reduction in assets due to redemption. Please confirm that this did not change the fee table in the prospectus. In other words, confirm that you used the annual report numbers in the fee table in the prospectus.
Response: The Fund used the annual report numbers in the fee table in the prospectus. The Fund considered restating based on the redemptions, but determined that a restatement was not necessary due to various factors, including the fact that assets under management had stabilized. And, in fact, while the expense ratios have fluctuated throughout the fiscal year based on the gold market, the current ratios are not materially different from those presented in the prospectus.
Very truly yours,
/s/ Peter D. Fetzer
Peter D. Fetzer
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