Chicago New York Washington, DC London San Francisco Los Angeles Singapore vedderprice.com |
April 27, 2017 | Renee M. Hardt Shareholder +1 312 609 7616 rhardt@vedderprice.com |
Via Edgar
Ms. Deborah O’Neal-Johnson |
Re: | The Oberweis Funds Post-Effective Amendment Nos. 52 and 53 | |
(File Nos. 33-9093 and 811-4854) |
Dear Ms. O’Neal-Johnson:
On behalf of The Oberweis Funds (the “Trust”), this letter is in response to the comments you provided on April 3, 2017 during our telephone conference regarding the post-effective amendment filings of the Trust made on February 1, 2017 (No. 52) and March 1, 2017 (No. 53).
Post-Effective Amendment No. 52 – Prospectus
1. | General |
a. | Comment: Please confirm supplementally whether the Institutional Class shares will be used as “Clean Shares.” |
Response: The Trust does not currently intend to use the Institutional Class shares as Clean Shares for whichfor which brokers could charge customers commissions to effect transactions.
2. | Fees and Expenses of the Fund |
Comment: Please provide a completed fee table and expense examples prior to the effective date.
Response: The Trust has provided the staff with a completed fee table and expense examples.
3. | Principal Investment Strategies |
a. | Comment: The Principal Investment Strategies section in the summary seems long. Please consider shortening it. |
Response: The Trust believes the current disclosure is appropriate given the Micro-Cap Fund’s principal investment strategies. Accordingly, no change has been made in response to this comment.
Ms. Deborah O’Neal-Johnson
April 27, 2017
Page 2
b. | Comment: Please confirm supplementally whether the Micro-Cap Fund may invest in non-U.S. or fixed income securities. |
Response: The Fund does not invest in non-U.S. or fixed income securities as part of its principal investment strategy.
c. | Comment: Please add disclosure regarding the capitalization range of the Russell Micro-Cap Growth Index as of its most recent rebalancing date. |
Response: The following sentence has been added after the first sentence of the first paragraph: As of March 31, 2017, the market capitalization range of the Russell Micro-Cap Growth Index was $11.6 million to $1.7 billion.
d. | Comment: If the Micro-Cap Fund’s 80% policy is not fundamental, disclose this fact and any policy to notify shareholders of a change. |
Response: The Fund’s 80% policy is not fundamental. The following disclosure has been added to the end of the section entitled “Investment Objectives, Policies and Risks – Investment Objectives of the Funds”: Each Fund may change its 80% investment policy (as stated above) subject to approval by the Board of Trustees and at least 60 days’ prior notice to Fund shareholders.
4. | Fund Performance |
Comment: Please provide completed performance information to the staff prior to the effective date.
Response: The Trust has provided the staff with completed performance information.
Post-Effective Amendment No. 53 – Prospectus
5. | General |
a. | Comment: Please confirm supplementally whether the Institutional Class shares will be used as “Clean Shares.” |
Response: The Trust does not currently intend to use the Institutional Class shares as Clean Sharesfor which brokers could charge customers commissions to effect transactions.
Ms. Deborah O’Neal-Johnson
April 27, 2017
Page 3
6. | Fees and Expenses of the Fund |
a. | Comment: Please provide completed fee tables and expense examples prior to the effective date. |
Response: The Trust has provided the staff with completed fee tables and expense examples.
b. | Comment: Please explain why expenses are estimated for Institutional Class shares when the Funds have been in operations. |
Response: Since the class is new, the Funds are not able to specifically calculate other expenses, and thus, other expenses are estimated.
c. | Comment: For any Fund with a footnote regarding an expense limitation agreement, please add the following to the end of the last sentence: in place at the time of the reimbursement or currently, whichever is less. |
Response: The sentence has been revised accordingly.
d. | Comment: Please confirm supplementally that any expense limitation reflected in the expense examples only applies for the duration of the expense limitation agreement. |
Response: The Trust confirms that any expense limitation reflected in the expense examples only applies for the duration of the expense limitation agreement.
7. | Principal Investment Strategies |
Comment: Please confirm that the disclosure regarding the Funds’ derivative instruments is in substantial conformity with the Division of Investment Management’s guidance about derivative-related disclosure by investment companies, dated July 30, 2010.
Response: The Trust so confirms.
8. | Fund Performance |
Comment: Please provide completed performance information to the staff prior to the effective date.
Response: The Trust has provided the staff with completed performance information.
* * *
Please call me at (312) 609-7616 if you have any questions.
Ms. Deborah O’Neal-Johnson
April 27, 2017
Page 4
Very truly yours,
/s/ Renee M. Hardt
Renee M. Hardt
|
RMH/ser
cc: | Patrick B. Joyce James A. Arpaia |