MFS® INVESTMENT MANAGEMENT
111 Huntington Avenue, Boston, Massachusetts 02199
Phone 617-954-5000
September 24, 2021
VIA EDGAR (as Correspondence)
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
RE: | Post-Effective Amendment No. 164 to Registration Statement on Form N-1A for MFS Series Trust X (the "Trust" or the "Registrant") on behalf of MFS Aggressive Growth Allocation Fund, MFS Conservative Allocation Fund, MFS Growth Allocation Fund, and MFS Moderate Allocation Fund (the "Funds") (File Nos. 33-01657 and 811-04492) |
Ladies and Gentlemen:
On behalf of the Trust, this letter sets forth our responses to your comments of September 14, 2021, on the above-referenced Post-Effective Amendment (the "PEA"), filed with the U.S. Securities and Exchange Commission (the "SEC") on July 29, 2021. The PEA was filed for the purpose of registering Class R6 shares of the Funds. Any term that is used, but not defined, in this letter retains the same meaning as used by the Registrant in the PEA.
Prospectus Comments
1. | Comment: | For Class R6 shares, please confirm the "Performance Table" shows either: (i) the performance of an existing class restated to reflect the maximum sales load set forth in the "Fees and Expenses" table for Class R6 shares (in this case, confirm the Class R6 shares are not more expensive than the class shown); or (ii) the performance of an existing class adjusted to reflect the gross annual operating expenses set forth in the "Fees and Expenses" table for Class R6 shares. If approach (ii) is used, make sure the conditions of the Quest for Value Dual Purpose Fund, Inc. No Action Letter (pub. avail. Feb. 28, 1997) are followed. Among other things, the proposed adjustment to reflect the gross annual operating expenses should not result in a higher total return figure. |