| Re: | New Century Portfolios |
| SEC File Nos. 33-24041 / 811-5646 |
| Post-Effective Amendment No. 30 |
| Staff Comment | Response | Checked items apply to ALL applicable Summary sections | |
Summary Section, Generally | |||
| 1 | Prior to using the Summary Prospectus for any fund, provide the U.S. Securities and Exchange Commission with a draft of the legend required by Rule 498(b)(1)(v) under the Securities Act of 1933 | if the Registrant uses the Summary Prospectus, the legend would read as set forth below this table | X |
| 2 | Remove the ticker symbol from the beginning of each fund’s summary section | removed | X |
| Summary Section, New Century Capital Portfolio | |||
| 3 | Following the Shareholder Fees table, delete the asterisked footnote, shorten the text contained therein, and add it to the parenthetical following the “Redemption Fees” line item in the table | deleted, shortened and added | X |
| 4 | In the Annual Operating Expenses table, add the word “Fund” between the words “Annual” and “Operating”, both in the title and in the final line item in the table | added | X |
| 5 | Following the Annual Operating Expenses table, delete footnotes 1 through 3, and re-number footnote 4 accordingly (and make conforming changes in the table), | deleted, renumbered and changed | X |
| 6 | In the Principal Investment Strategies portion of the summary section, add a reference regarding investing in ETFs | added | X |
| 7 | Delete the first paragraph in the Principal Investment Risks portion of the summary section, though the Registrant may retain the sentence that reads “You may lose money by investing in the Portfolio.” | the Registrant has deleted the entire paragraph | X |
| 8 | In the Principal Investment Risks portion of the summary section, delete the paragraph titled “Risks in General” | deleted | X |
| 9 | In the Principal Investment Risks portion of the summary section, separate the “Equity and Market Capitalization Risk” paragraph into two separate paragraphs | separated | X |
| 10 | In the “Investment Company and ETF Risk” add a disclosure regarding the layering of fees and expenses involved with investing in other investment companies | added | X |
| 11 | In the Principal Investment Risks portion of the summary section, delete the paragraph that begins “You should consider your own investment goals…” | deleted | X |
| 12 | In the paragraph following the “Performance”, delete the sentence that reads “Both assume that all dividends and distributions are reinvested in the Portfolio” | deleted | X |
| 13 | In the same paragraph, change the reference to the “bar chart” in the second line with the word “table” | changed | X |
| 14 | In the Average Annual Total Returns bar chart, provide updated performance through 12/31/2009, if possible | the returns in the bar chart reflect performance returns through 12/31/2009 | X |
| 15 | Following the Average Annual Total Returns table, change the “After-tax returns…” from a footnote into a narrative paragraph (and delete the corresponding references in the table) | changed | X |
| Summary Section, New Century Balanced Portfolio (in addition to comments carried over from above) | |||
| 16 | In the Principal Investment Strategies portion of the summary section, add a disclosure related to investments in emerging markets | added | |
| 17 | Change footnote 2 following the Average Annual Total Returns table into a narrative paragraph, and move it to before the Average Annual Total Returns bar chart | changed and moved | X (to the extent that the other summary sections contain a similar footnote) |
| 18 | In the same paragraph noted in response 15 above, add a discussion of the relevance and application of any supplemental index(es) listed in the Average Annual Total Returns table to the Portfolio | added | X (to the extent that the other summary sections contain a supplemental index) |
| Summary Section, New Century Opportunistic Portfolio (in addition to comments carried over from above) | |||
| 19 | In the Annual Fund Operating Expenses table, add two new line items after the “Total annual fund operating expenses” line item, the first indicating the amount of the fee waiver / expense reimbursement and the second indicating the total annual fund operating expenses after applying the fee waiver / expense reimbursement | added |
| 20 | In the footnote discussing the fee waiver / expense reimbursement agreement, add an explanation about who may terminate the agreement and under what conditions they may do so | added | |
| Summary Section, New Century International Portfolio (in addition to comments carried over from above) | |||
| 21 | You inquired as to whether this fund invests in fixed income securities of at least intermediate duration, and if so, add a credit risk and maturity risk to the Principal Investment Risks portion of the summary section, and add corresponding Principal Investment Strategies | this fund does not invest in these types of securities; however, see the following item regarding the New Century Alternative Strategies Portfolio | |
| Summary Section, New Century Alternative Strategies Portfolio (in addition to comments carried over from above) | |||
| 22 | We applied your comment above regarding credit risk and maturity risk to this fund and to the New Century Balanced Portfolio | added | |
| 23 | In the Principal Investment Risks portion of the summary section, add an interest rate risk, if applicable | added | |
| 24 | In the Principal Investment Risks portion of the summary section, add a distressed companies risk, if applicable | added | |
| Prospectus Body | |||
| 25 | In the paragraph following the “Tax Information” heading, add a disclosure that clarifies that income received by investors investing through tax-deferred arrangements will be subject to income or capital gains taxes at a later date | added |
| 26 | Add the words “Information on” following the word “Additional” in the heading that reads “Additional Principal Risks of Investing in the Portfolios” | added | |
| 27 | Verify that each of the risks discussed in the “Additional Information on Principal Risks of Investing in the Portfolios” section is discussed in the summary section of at least one fund | verified | |
| 28 | If the investment by any fund in other investment companies, including ETFs, that concentrate on a particular industry would have the effect of causing the fund to be concentrated in a particular industry, disclose that information in the risk/return portion of the summary section for such fund | none of the funds are concentrated in any particular industry, despite investments in other investment companies, including ETFs, that concentrate in particular industries | |
| Back Cover Page | |||
| 29 | Change the zip code for the SEC Public Reference Section to “20549-1520” | changed |
