Transamerica Asset Management, Inc. 1801 California Street, Suite 5200 Denver, Colorado 80202 (720) 482-1574 | ||
June 15, 2016
VIA EDGAR CORRESPONDENCE
Mr. Keith A. Gregory
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549-0102
Re: | Transamerica Funds (the “Registrant”) |
(File Nos. 033-02659; 811-04556)
Dear Mr. Gregory:
On behalf of the Registrant, we are filing this letter to respond in writing to the Staff’s comment on the Registration Statement filed under Rule 485(a) of the Securities Act of 1933, as amended (the “1933 Act”), on Form N-1A (Accession Number: 0001193125-16-600480) with the Securities and Exchange Commission (the “Commission”) on May 24, 2016, relating to the registration of a new “Advisor Class” for thirty-one existing series of the Registrant and the addition of “R6” Class shares to four other existing series of the Registrant (each individual series a “Fund” and collectively, the “Funds”). The Staff’s comment was conveyed to the Registrant by telephone on June 13, 2016.
The Staff requested that the Registrant provide, via Edgar Correspondence, the information required by Form N-1A in the “Annual Fund Operating Expenses” section of the prospectuses, including all line items and footnotes for each Fund. The registrant furnishes the requested information below.
ADVISOR CLASS
Transamerica Capital Growth
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.75 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.22 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.97 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica Concentrated Growth
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.68 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.20 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.88 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
1
Transamerica Dividend Focused
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.67 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.20 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.87 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica Emerging Markets Debt
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.62 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.24 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.86 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica Emerging Markets Equity
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.98 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.33 | % | ||||
|
| |||||
Total annual fund operating expenses | 1.31 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica Event Driven
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||||||
Management fees | 1.19 | % | ||||||||
Distribution and service (12b-1) fees | None | |||||||||
Other expenses1 | 1.93 | % | ||||||||
Dividend, interest and borrowing expense on securities sold short2 | 1.11 | % | ||||||||
All other expenses | 0.82 | % | ||||||||
Acquired fund fees and expenses | 0.06 | % | ||||||||
|
| |||||||||
Total annual fund operating expenses | 3.18 | % | ||||||||
|
| |||||||||
Fee waiver and/or expense reimbursement3 | 0.35 | % | ||||||||
|
| |||||||||
Total annual fund operating expenses after fee waiver and/or expense reimbursement4 | 2.83 | % | ||||||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Dividend expense on securities sold short refers to paying the value of dividends to the securities’ lenders. Interest expense on securities sold short arises from the use of short sale proceeds to invest more than 100% of the fund’s net assets in long positions. |
3 | Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through [March 1, 2017] to waive fees and/or reimburse fund expenses to the extent that the fund’s total operating expenses exceed [1.35%], excluding, as applicable, 12b-1 fees, acquired fund fees and expenses, interest, taxes, brokerage |
2
commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to [March 1, 2017] without the Board of Trustees’ consent. TAM is entitled to recapture amounts waived and/or reimbursed to a class during any of the previous 36 months if the class’s total annual operating expenses have fallen to a level below the limit described above. |
4 | Total annual fund operating expenses do not correlate to the ratios of expenses to average net assets in the financial highlights table, which do not include acquired (i.e., underlying) funds’ fees and expenses or borrowing expenses on securities sold short. |
Transamerica Flexible Income
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.46 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.20 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.66 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica Floating Rate
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.64 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.29 | % | ||||
Acquired fund fees and expenses | 0.01 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.94 | % | ||||
|
| |||||
Fee waiver and/or expense reimbursement2 | 0.13 | % | ||||
|
| |||||
Total annual fund operating expenses after fee waiver and/or expense reimbursement3 | 0.81 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through [March 1, 2017] to waive fees and/or reimburse fund expenses to the extent that the fund’s total operating expenses exceed [0.80%], excluding, as applicable, 12b-1 fees, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to [March 1, 2017] without the Board of Trustees’ consent. TAM is entitled to recapture amounts waived and/or reimbursed to a class during any of the previous 36 months if the class’s total annual operating expenses have fallen to a level below the limit described above. |
3 | Total annual fund operating expenses do not correlate to the ratios of expenses to average net assets in the financial highlights table, which do not include acquired (i.e., underlying) funds’ fees and expenses or borrowing expenses on securities sold short. |
Transamerica Global Bond
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.57 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.41 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.98 | % | ||||
|
|
3
Fee waiver and/or expense reimbursement2 | 0.23 | % | ||||
|
| |||||
Total annual fund operating expenses after fee waiver and/or expense reimbursement | 0.75 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through [March 1, 2017] to waive fees and/or reimburse fund expenses to the extent that the fund’s total operating expenses exceed [0.75%], excluding, as applicable, 12b-1 fees, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to [March 1, 2017] without the Board of Trustees’ consent. TAM is entitled to recapture amounts waived and/or reimbursed to a class during any of the previous 36 months if the class’s total annual operating expenses have fallen to a level below the limit described above. |
Transamerica Global Equity
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.84 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.25 | % | ||||
Acquired fund fees and expenses | 0.01 | % | ||||
|
| |||||
Total annual fund operating expenses2 | 1.10 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Total annual fund operating expenses do not correlate to the ratios of expenses to average net assets in the financial highlights table, which do not include acquired (i.e., underlying) funds’ fees and expenses or borrowing expenses on securities sold short. |
Transamerica Global Long/Short Equity
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||||||
Management fees | 1.03 | % | ||||||||
Distribution and service (12b-1) fees | None | |||||||||
Other expenses1 | 2.72 | % | ||||||||
|
| |||||||||
Dividend, interest and borrowing expense on securities sold short | 2.09 | % | ||||||||
All other expenses | 0.63 | % | ||||||||
Total annual fund operating expenses | 3.75 | % | ||||||||
|
| |||||||||
Fee waiver and/or expense reimbursement2 | 0.11 | % | ||||||||
|
| |||||||||
Total annual fund operating expenses after fee waiver and/or expense reimbursement | 3.64 | % | ||||||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through [March 1, 2017] to waive fees and/or reimburse fund expenses to the extent that the fund’s total operating expenses exceed [1.55%], excluding, as applicable, 12b-1 fees, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to [March 1, 2017] without the Board of Trustees’ consent. TAM is entitled to recapture amounts waived and/or reimbursed to a class during any of the previous 36 months if the class’s total annual operating expenses have fallen to a level below the limit described above. |
4
Transamerica High Yield Bond
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.58 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.21 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.79 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica High Yield Muni
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.54 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.58 | % | ||||
Acquired fund fees and expenses | 0.01 | % | ||||
|
| |||||
Total annual fund operating expenses | 1.13 | % | ||||
|
| |||||
Fee waiver and/or expense reimbursement2 | 0.36 | % | ||||
|
| |||||
Total annual fund operating expenses after fee waiver and/or expense reimbursement3 | 0.77 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through [March 1, 2017] to waive fees and/or reimburse fund expenses to the extent that the fund’s total operating expenses exceed [0.76%], excluding, as applicable, 12b-1 fees, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to [March 1, 2017] without the Board of Trustees’ consent. TAM is entitled to recapture amounts waived and/or reimbursed to a class during any of the previous 36 months if the class’s total annual operating expenses have fallen to a level below the limit described above. |
3 | Total annual fund operating expenses do not correlate to the ratios of expenses to average net assets in the financial highlights table, which do not include acquired (i.e., underlying) funds’ fees and expenses or borrowing expenses on securities sold short. |
Transamerica Income & Growth
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.69 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.21 | % | ||||
Acquired fund fees and expenses | 0.24 | % | ||||
|
| |||||
Total annual fund operating expenses2 | 1.14 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Total annual fund operating expenses do not correlate to the ratios of expenses to average net assets in the financial highlights table, which do not include acquired (i.e., underlying) funds’ fees and expenses or borrowing expenses on securities sold short. |
Transamerica Inflation Opportunities
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.58 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.26 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.84 | % | ||||
|
|
5
Fee waiver and/or expense reimbursement2 | 0.09 | % | ||
|
| |||
Total annual fund operating expenses after fee waiver and/or expense reimbursement | 0.75 | % | ||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through [March 1, 2017] to waive fees and/or reimburse fund expenses to the extent that the fund’s total operating expenses exceed [0.75%], excluding, as applicable, 12b-1 fees, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to [March 1, 2017] without the Board of Trustees’ consent. TAM is entitled to recapture amounts waived and/or reimbursed to a class during any of the previous 36 months if the class’s total annual operating expenses have fallen to a level below the limit described above. |
Transamerica Intermediate Bond
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.38 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.18 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.56 | % | ||||
|
| |||||
Fee waiver and/or expense reimbursement2 | 0.01 | % | ||||
|
| |||||
Total annual fund operating expenses after fee waiver and/or expense reimbursement | 0.55 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through [March 1, 2017] to waive fees and/or reimburse fund expenses to the extent that the fund’s total operating expenses exceed 0.55%, excluding, as applicable, 12b-1 fees, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to [March 1, 2017] without the Board of Trustees’ consent. TAM is entitled to reimbursement by the fund of fees waived or expenses reduced during any of the previous 36 months if on any day or month the estimated annualized fund operating expenses are less than the cap. |
Transamerica Intermediate Muni (formerly, Transamerica Enhanced Muni)
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||||||
Management fees | 0.46 | % | ||||||||
Distribution and service (12b-1) fees | None | |||||||||
Other expenses1 | 0.30 | % | ||||||||
|
| |||||||||
Recaptured expense2 | 0.01 | % | ||||||||
All other expenses | 0.29 | % | ||||||||
Total annual fund operating expenses | 0.76 | % | ||||||||
|
| |||||||||
Fee waiver and/or expense reimbursement2 | 0.05 | % | ||||||||
|
| |||||||||
Total annual fund operating expenses after fee waiver and/or expense reimbursement | 0.71 | % | ||||||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through [March 1, 2017] to waive fees and/or reimburse fund expenses to the extent that the fund’s total operating expenses exceed [0.71%], excluding, as applicable, 12b-1 fees, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to [March 1, 2017] without the Board of Trustees’ consent. TAM is entitled to reimbursement by the fund of fees waived or expenses reduced during any of the previous 36 months if on any day or month the estimated annualized fund operating expenses are less than the cap. |
6
Transamerica International Equity
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.74 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.24 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.98 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica Large Cap Value
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.65 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.18 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.83 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica Mid Cap Growth
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.75 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.23 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.98 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica Mid Cap Value Opportunities
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.70 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.19 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.89 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica MLP & Energy Income
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 1.08 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.21 | % | ||||
|
| |||||
Total annual fund operating expenses | 1.29 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
7
Transamerica Multi-Cap Growth (formerly, Transamerica Growth Opportunities)
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.70 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.26 | % | ||||
|
| |||||
Total annual fund operating expenses2 | 0.96 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Total annual fund operating expenses do not correlate to the ratios of expenses to average net assets in the financial highlights table, which do not include acquired (i.e., underlying) funds’ fees and expenses or borrowing expenses on securities sold short. |
Transamerica Short-Term Bond
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.49 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.19 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.68 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica Small Cap Core
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.83 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.23 | % | ||||
|
| |||||
Total annual fund operating expenses | 1.06 | % | ||||
|
| |||||
Fee waiver and/or expense reimbursement2 | 0.01 | % | ||||
|
| |||||
Total annual fund operating expenses after fee waiver and/or expense reimbursement | 1.05 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through [March 1, 2017] to waive fees and/or reimburse fund expenses to the extent that the fund’s total operating expenses exceed [1.05%], excluding, as applicable, 12b-1 fees, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to [March 1, 2017] without the Board of Trustees’ consent. TAM is entitled to reimbursement by the fund of fees waived or expenses reduced during any of the previous 36 months if on any day or month the estimated annualized fund operating expenses are less than the cap. |
Transamerica Small Cap Growth
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.85 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.20 | % | ||||
|
| |||||
Total annual fund operating expenses | 1.05 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
8
Transamerica Small Cap Value
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.82 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.22 | % | ||||
Acquired fund fees and expenses | 0.32 | % | ||||
|
| |||||
Total annual fund operating expenses2 | 1.36 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Total annual fund operating expenses do not correlate to the ratios of expenses to average net assets in the financial highlights table, which do not include acquired (i.e., underlying) funds’ fees and expenses or borrowing expenses on securities sold short. |
Transamerica Small/Mid Cap Value
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.80 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.20 | % | ||||
|
| |||||
Total annual fund operating expenses | 1.00 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica Strategic High Income
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.69 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.46 | % | ||||
Acquired fund fees and expenses | 0.02 | % | ||||
|
| |||||
Total annual fund operating expenses | 1.17 | % | ||||
|
| |||||
Fee waiver and/or expense reimbursement2 | 0.20 | % | ||||
|
| |||||
Total annual fund operating expenses after fee waiver and/or expense reimbursement3 | 0.97 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through [March 1, 2017] to waive fees and/or reimburse fund expenses to the extent that the fund’s total operating expenses exceed [0.95%], excluding, as applicable, 12b-1 fees, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to [March 1, 2017] without the Board of Trustees’ consent. TAM is entitled to recapture amounts waived and/or reimbursed to a class during any of the previous 36 months if the class’s total annual operating expenses have fallen to a level below the limit described above. |
3 | Total annual fund operating expenses do not correlate to the ratios of expenses to average net assets in the financial highlights table, which do not include acquired (i.e., underlying) funds’ fees and expenses or borrowing expenses on securities sold short. |
9
Transamerica Unconstrained Bond
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.67 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.43 | % | ||||
|
| |||||
Total annual fund operating expenses | 1.10 | % | ||||
|
| |||||
Fee waiver and/or expense reimbursement2 | 0.15 | % | ||||
|
| |||||
Total annual fund operating expenses after fee waiver and/or expense reimbursement | 0.95 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
2 | Contractual arrangements have been made with the fund’s investment manager, Transamerica Asset Management, Inc. (“TAM”), through [March 1, 2017] to waive fees and/or reimburse fund expenses to the extent that the fund’s total operating expenses exceed [0.95%], excluding, as applicable, 12b-1 fees, acquired fund fees and expenses, interest, taxes, brokerage commissions, dividend and interest expenses on securities sold short, extraordinary expenses and other expenses not incurred in the ordinary course of the fund’s business. These arrangements cannot be terminated prior to [March 1, 2017] without the Board of Trustees’ consent. TAM is entitled to recapture amounts waived and/or reimbursed to a class during any of the previous 36 months if the class’s total annual operating expenses have fallen to a level below the limit described above. |
Transamerica US Growth
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | Advisor | |||||
Management fees | 0.69 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.22 | % | ||||
|
| |||||
Total annual fund operating expenses | 0.91 | % | ||||
|
|
1 | Other expenses are based on estimates for the current fiscal year. |
R6 CLASS
Transamerica Inflation Opportunities
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | R6 | |||||
Management fees | 0.58 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.08 | % | ||||
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Total annual fund operating expenses | 0.66 | % | ||||
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1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica Mid Cap Value Opportunities
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | R6 | |||||
Management fees | 0.70 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.05 | % | ||||
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Total annual fund operating expenses | 0.75 | % | ||||
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1 | Other expenses are based on estimates for the current fiscal year. |
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Transamerica Small Cap Growth
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | R6 | |||||
Management fees | 0.85 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.04 | % | ||||
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Total annual fund operating expenses | 0.89 | % | ||||
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1 | Other expenses are based on estimates for the current fiscal year. |
Transamerica Small Cap Value
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Class: | R6 | |||||
Management fees | 0.82 | % | ||||
Distribution and service (12b-1) fees | None | |||||
Other expenses1 | 0.04 | % | ||||
Acquired fund fees and expenses | 0.32 | % | ||||
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Total annual fund operating expenses2 | 1.18 | % | ||||
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1 | Other expenses are based on estimates for the current fiscal year. |
2 | Total annual fund operating expenses do not correlate to the ratios of expenses to average net assets in the financial highlights table, which do not include acquired (i.e., underlying) funds’ fees and expenses. |
*****
The Registrant acknowledges that, with respect to filings made by the Registrant with the Commission and reviewed by the Staff:
(a) | the Registrant is responsible for the adequacy and accuracy of the disclosure in the filings; |
(b) | Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filings; and |
(c) | the Registrant 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. |
Please call the undersigned at (720) 482-1574 with any questions.
Very truly yours, |
/s/ Tané T. Tyler |
Tané T. Tyler |
Vice President, Assistant General Counsel, |
Chief Legal Officer and Secretary |
Transamerica Asset Management, Inc. |
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