[ON CHAPMANAND CUTLER LLP LETTERHEAD]
February 23, 2018
VIA EDGAR CORRESPONDENCE
Elizabeth Bentzinger
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| | | | |
| | Re: | | Nuveen Investment Funds, Inc. |
| | | | File Nos.033-16905 and811-05309 |
Dear Ms. Bentzinger:
This letter responds to your comments given during a telephone conversation with our office on February 8, 2018, regarding the registration statement filed onForm N-1A for Nuveen Investment Funds, Inc. (the“Trust”) with the Securities and Exchange Commission (the“Commission”) on December 22, 2017, which relates to Nuveen Small Cap Select Fund (the“Fund”), a series of the Trust. The prospectus and statement of additional information for the Fund have been revised in response to your comments.
GENERAL COMMENT
COMMENT 1
Please provide the ticker symbol for Class R6 shares on the cover pages of the prospectus and statement of additional information and on EDGAR once you obtain them.
RESPONSETO COMMENT 1
The ticker symbol has been added to the cover pages and has been updated on EDGAR.
PROSPECTUS
COMMENT 2 — FUND SUMMARY — FEESAND EXPENSESOFTHE FUND
Footnote 5 to the “Annual Fund Operating Expenses” table states that other expenses are estimated for the current fiscal year for Class R6 shares. Please explain supplementally why the Fund expects the expenses for Class R6 shares to be materially different from other share classes.
RESPONSETO COMMENT 2
The expenses for Class R6 shares are estimated for the current fiscal year because Class R6 shares are not subject tosub-transfer agent and similar fees. Consequently, the expenses for Class R6 shares are estimated by taking the expenses for Class I shares and subtractingsub-transfer agent and similar fees based on a recent calculation of such fees.
COMMENT 3 — FUND SUMMARY — FEESAND EXPENSESOFTHE FUND
Please confirm supplementally that the Fund believes that the numbers in the “Example” table accurately reflect the fees of the various share classes in its calculations.
RESPONSETO COMMENT 3
Management confirms that the numbers in the “Example” table accurately reflect the fees of the various share classes in its calculations.
COMMENT 4 — HOW WE MANAGE YOUR MONEY — MORE ABOUT OUR INVESTMENT STRATEGIES — ETFSAND OTHER INVESTMENT COMPANIES
Please confirm that the fees and expenses incurred indirectly by the Fund as a result of investing in other investment companies do not exceed 0.01% of the average net assets of the Fund. Otherwise, please include the appropriate line item in the “Annual Fund Operating Expenses” table.
RESPONSETO COMMENT 4
Management confirms that the fees and expenses incurred indirectly by the Fund as a result of investing in other investment companies do not exceed 0.01% of the average net assets of the Fund.
COMMENT 5 — HOW YOU CAN BUYAND SELL SHARES — WHAT SHARE CLASSES WE OFFER — CONTINGENT DEFERRED SALES CHARGES
Please confirm supplementally that all of the information regarding sales charge waivers required by Item 12(a)(2) of FormN-1A is described in the prospectus, except for the information required by Items 17(d) and 23(b) of FormN-1A.
RESPONSETO COMMENT 5
Management confirms that all of the information regarding sales charge waivers required by Item 12(a)(2) of FormN-1A is described in the prospectus, except for the information required by Items 17(d) and 23(b) of FormN-1A.
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COMMENT 6 — HOW YOU CAN BUYAND SELL SHARES — HOWTO REDUCE YOUR SALES CHARGE
In the first paragraph, please include disclosure that the sales charge for Class T shares may be waived.
RESPONSETO COMMENT 6
As stated in the appendix to the prospectus, currently there are no intermediaries offering sales charge waivers for Class T shares. To the extent such waivers are made available in the future, the relevant disclosure will be added to this section.
COMMENT 7 — HOW YOU CAN BUYAND SELL SHARES — HOWTO REDUCE YOUR SALES CHARGE
Under the “CDSC Waivers and Reductions” section, please confirm that the intermediaries referenced in the seventh and eighth bullets are listed in the appendix to the prospectus or remove these bullets.
RESPONSETO COMMENT 7
The situations described in the two referenced bullets are available to shareholders through any intermediary under the circumstances described. Because the waivers are not limited to only a certain intermediary or intermediaries, no intermediaries are listed in the appendix to the prospectus with respect to these waivers. Consequently, management respectfully declines to make the requested revision.
COMMENT 8 — HOW YOU CAN BUYAND SELL SHARES — SPECIAL SERVICES
Please confirm that the disclosure under the “Reinstatement Privilege” section is current.
RESPONSETO COMMENT 8
The first sentence of this section has been revised to state: “If you redeem Class A, Class C or Class I shares, you may reinvest all or part of your redemption proceeds up to one year later without incurring any additional charges.”
STATEMENTOF ADDITIONAL INFORMATION
COMMENT 9 — INVESTMENT POLICIESAND TECHNIQUES
The first sentence of the second paragraph under the “Lending of Portfolio Securities” section states that “the Fund will receive collateral in the form of cash, U.S. government securities or other high-grade debt obligations.” Collateral can only be in the form of cash, U.S. government securities and irrevocable bank standby letters of credit that are not issued by the Fund’s bank lending agent. Please provide the rationale for including other high-grade debt obligations.
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RESPONSETO COMMENT 9
The first two sentences of the second paragraph under the “Lending of Portfolio Securities” section have been revised to state: “In these loan arrangements, the Fund will receive cash collateral equal to at least 102% of the value of the securities loaned as determined at the time of loan origination. If the market value of the loaned securities increases, the borrower must furnish additional collateral to the lending Fund.”
Please call me at(312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.
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Sincerely yours, |
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CHAPMANAND CUTLERLLP |
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By: | | /s/ Morrison C. Warren |
| | Morrison C. Warren |
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