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Frederick H. Sherley
frederick.sherley@dechert.com +1 704 339 3151 Direct +1 704 339 3171 Fax |
August 15, 2011
VIA EDGAR
Division of Investment Management
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Attn: Linda Stirling, Esq.
Re: | HSBC Investor Funds (the “Registrant”) |
Dear Ms. Stirling:
This letter responds to the comments that you provided telephonically on August 11, 2011 in connection with the Registrant’s pre-effective proxy statement relating to the Aggressive Strategy Fund, Moderate Strategy Fund, Balanced Strategy Fund and Conservative Strategy Fund (the “Funds”). A definitive proxy statement has been filed today. Summaries of the comments, and our responses thereto, are provided below.
Comment 1:On page 3 of the preliminary proxy statement as filed, in the paragraph discussing the expense limitation agreement, please clarify whether the expense limitation terminates with the old advisory agreement. Assuming that it does not, please clarify that the limitation will apply through March 31, 2012 under the new contract.
Response: This point has been clarified. Please refer to the same paragraph as filed in the definitive proxy statement.
Comment 2:Please amend the Fee Tables so that the expense limitation is referenced only in the footnotes.
Response: After careful consideration, the Registrant respectfully declines to accept this comment out of a concern about the inconsistency this approach would create with the corresponding prospectus disclosure.
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| Ms. Linda Stirling August 15, 2011 Page 2 |
Comment 3:For the Expense Examples, please revise to omit the effects of the expense limitation arrangement.
Response: After careful consideration, the Registrant respectfully declines to accept this commentout of a concern about the inconsistency this approach would create with the corresponding prospectus disclosure.
Please contact me at 704.339.3151 if you have any questions.
Very truly yours,
/s/ Frederick H. Sherley
Frederick H. Sherley
FHS