[ON CHAPMANAND CUTLER LLP LETTERHEAD]
January 20, 2015
VIA EDGAR CORRESPONDENCE
Alison White
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Nuveen Investment Funds, Inc. | |
| File Nos. 811-05309 and 033-16905 |
Dear Ms. White:
This letter responds to your comments given during a telephone conversation with our office on December 8, 2014 regarding the registration statement filed on Form N-1A for Nuveen Investment Funds, Inc. (the“Trust”) with the Securities and Exchange Commission (the“Commission”) on November 18, 2014, which relates to Nuveen Core Bond Fund, Nuveen Core Plus Bond Fund, Nuveen Inflation Protected Securities Fund, Nuveen Short Term Bond Fund and Nuveen Strategic Income Fund (individually, a“Fund” and collectively, the“Funds”), each a series of the Trust. The prospectus and statement of additional information for the Funds have been revised in response to your comments.
ALL FUNDS
GENERAL COMMENTS
COMMENT 1
Please include the Tandy representations in the response letter.
RESPONSETO COMMENT 1
The Tandy representations are included at the end of this response letter.
PROSPECTUS
COMMENT 2 — COVER PAGE
Please provide the ticker symbols for Class R6 on the cover page once you obtain it.
RESPONSETO COMMENT 2
The ticker symbols have been added to the cover page.
COMMENT 3 — FUND SUMMARY — FEESAND EXPENSESOFTHE FUND
In each Fund’s “Annual Fund Operating Expenses” table, please confirm that the fee waiver explained in footnote 3 does not apply to Class R6 shares or revise the disclosure.
RESPONSETO COMMENT 3
The fee waiver applies to Class R6 shares and the disclosure in footnote 3 has been revised accordingly.
COMMENT 4 — FUND SUMMARY — FEESAND EXPENSESOFTHE FUND
In each Fund’s “Annual Fund Operating Expenses” table, please revise footnote 4 to state that the expenses for Class R6 shares are based on estimated amounts for the current fiscal year.
RESPONSETO COMMENT 4
The footnote disclosure has been revised in response to this comment.
COMMENT 5 — FUND SUMMARY — FEESAND EXPENSESOFTHE FUND
For each Fund, please confirm that the amounts that will be provided in the respective “Example” tables will reflect that Fund’s fee waiver and will only reflect the fee waiver for the period that it is expected to be in place.
RESPONSETO COMMENT 5
Management confirms that the amounts provided in the “Example” tables reflect the fee waivers only for the periods that they are expected to be in place.
COMMENT 6 — FUND SUMMARY — PRINCIPAL INVESTMENT STRATEGIES
The derivatives disclosure in each Fund is the same. Please tailor the derivatives descriptions for each Fund. Please review the guidance provided by the Division of Investment Management about derivative-related disclosure by investment companies in the letter from Barry D. Miller, Associate Director, Office of Legal and Disclosure, to Karrie McMillan, General Counsel, Investment Company Institute, dated July 30, 2010. In addition, please consider whether the risks of all of the identified derivatives are appropriately disclosed. As indicated in the guidance, the disclosure concerning the principal risks of the Fund should be tailored to the types of derivatives used by the Fund, the extent of their use, and the purpose for using derivative transactions.
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RESPONSETO COMMENT 6
Management confirms that the derivatives disclosure is properly tailored because each Fund may invest in the derivatives listed in the “Principal Investment Strategies” sections as a part of its principal investment strategy. Management also believes that the risk disclosure in the prospectus is consistent with theabove-referenced guidance. The risk disclosure describes the principal risks involved with the derivative instruments that may be used by each Fund.
COMMENT 7 — FUND SUMMARY — PRINCIPAL RISKS
Please revise the “Bond Market Liquidity Risk” disclosure to be in plain English.
RESPONSETO COMMENT 7
The risk disclosure has been revised in response to this comment.
COMMENT 8 — HOW WE MANAGE YOUR MONEY — WHO MANAGESTHE FUND
Under the “Management Fees” section, please clarify the meaning of “adjusted downward for Class R6 for savings resulting from the sub-transfer agent and similar fees that are not charged to the R6 shares.”
RESPONSETO COMMENT 8
The prospectus disclosure has been revised in response to this comment.
COMMENT 9 — HOW YOU CAN BUYAND SELL SHARES — HOWTO SELL SHARES — REDEMPTIONS IN-KIND
If the Fund will ever redeem shares in-kind with illiquid securities, please disclose this possibility and disclose that such illiquid securities may not be sellable.
RESPONSETO COMMENT 9
The prospectus disclosure has been revised in response to this comment.
NUVEEN CORE PLUS BOND FUND
PROSPECTUS
COMMENT 10
In the prospectus, please explain the meaning of the term “plus” in the name.
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RESPONSETO COMMENT 10
The term “plus” refers to the Fund’s ability to invest a higher amount in non-investment grade securities. This term is common in the marketplace. For example, the Lipper Fund Classifications includes a classification for “Core Plus Bond Funds,” which is generally defined as funds that invest at least 65% in domestic investment-grade debt issues with any remaining investment in non-benchmark sectors such as high-yield, global and emerging market debt.
ALL FUNDS
STATEMENTOF ADDITIONAL INFORMATION
COMMENT 11 — INVESTMENT POLICIESAND TECHNIQUES — CASH EQUIVALENTSAND SHORT-TERM INVESTMENTS
The “Cash Equivalents and Short-Term Investments” section states that “The Funds may temporarily invest without limit in [cash, cash equivalents, and in a variety of short-term investments] for liquidity purposes, or in an attempt to respond to adverse market, economic, political or other conditions.” Please include this disclosure in the prospectus, as required by instruction number 6 to Item 9(b)(1) of Form N-1A.
RESPONSETO COMMENT 11
On page 37, the second sentence under the “Cash Equivalents and Short-Term Investments” section states: “The Funds may temporarily invest without limit in such holdings for liquidity purposes, or in an attempt to respond to adverse market, economic, political or other conditions.”
COMMENT 12 — INVESTMENT POLICIESAND TECHNIQUES — DERIVATIVES
With regard to the total return swaps, please note that when the Funds engage in total return swaps, they must set aside an appropriate amount of segregated assets.Seegenerally Investment Company Act Release No. 10666 (Apr. 18, 1979). Also, note that the Commission issued a concept release exploring issues relating to the use of derivatives by funds, including whether current market practices involving derivatives are consistent with the leverage provisions of the Investment Company Act of 1940. See Investment Company Act Release No. 29776 (Aug. 31, 2011). Accordingly, please be aware that the Commission or its staff could issue future guidance related to derivatives (such as total return swaps) and leverage, including guidance related to coverage requirements, which could impact the manner in which the Funds operate. In addition, with regard to the credit default swaps, please confirm that when the Funds write or sell a credit default swap, the full notional value of the credit default swaps will be adequately covered.
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RESPONSETO COMMENT 12
Each Fund will set aside an appropriate amount of assets when it engages in total return swaps. In addition, each Fund will adequately cover the full notional value of a credit default swap only when it sells protection.
COMMENT 13 — DISCLOSUREOF PORTFOLIO HOLDINGS
Please disclose any policies and procedures with respect to the receipt of compensation or other consideration by the Fund, its investment adviser or any other party in connection with the disclosure of portfolio holdings.
RESPONSETO COMMENT 13
The statement of additional information disclosure has been revised in response to this comment.
COMMENT 14 — EXHIBITS
Please include a consent of the independent public accounting firm.
RESPONSETO COMMENT 14
A consent of the independent public accounting firm has been included as an exhibit.
Tandy Acknowledgment
In connection with the Trust’s registration statement, the Trust acknowledges that:
| • | it is responsible for the adequacy and accuracy of the disclosure in the filing; |
| • | 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 filing; and |
| • | the Trust 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. |
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Please call me at(312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.
Sincerely yours, | ||
CHAPMANAND CUTLERLLP | ||
By: | /s/ Morrison C. Warren | |
Morrison C. Warren | ||
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