The Integrity Funds
1 Main Street North
Minot, North Dakota 58703
Integrity Funds Distributor, LLC
1 Main Street North
Minot, North Dakota 58703
April 17, 2012
VIA EDGAR CORRESPONDENCE
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attention: Vincent DiStefano, Esq.
Re: | The Integrity Funds | |
| (Registration Nos. 33-53698 and 811-07322) | |
Ladies and Gentlemen:
The undersigned, The Integrity Funds (the "Registrant" or the "Trust") and Integrity Funds Distributor, LLC (the "Principal Underwriter"), pursuant to the provisions of Rule 461 of the General Rules and Regulations (the "General Rules") of the Securities and Exchange Commission (the "Commission") under the Securities Act of 1933 (the "1933 Act"), hereby respectfully request that the Commission grant acceleration of the effectiveness of Post-Effective Amendment No. 66 to the Registrant's Registration Statement on Form N-1A (the "Current Post-Effective Amendment") so that the same may become effective at 9:00 a.m., Eastern time, on May 1, 2012, or as soon thereafter as practicable.
The Current Post-Effective Amendment was filed on April 16, 2012 under Rule 485(a)(2) of the General Rules for the purpose of adding a new series, the Integrity Dividend Harvest Fund (the "Fund"), and, in accordance with Rule 485(d) of the General Rules, effectively supersedes Post-Effective Amendment No. 65 to the Registrant's Registration Statement on Form N-1A (the "Prior Post-Effective Amendment"). The Prior Post-Effective Amendment was filed under Rule 485(a)(2) of the General Rules on February 3, 2012, also for the purpose of adding the Fund, and otherwise would have become effective on April 18, 2012. On April 10, 2012, via an EDGAR Correspondence filing addressed to Vincent DiStefano of the Commission from Suzanne M. Russell of Chapman and Cutler LLP, the Registrant responded to the Commission's comments to the Prior Post-Effective Amendment and included a marked copy of the prospectus ("Prospectus") and statement of additional information ("SAI") for the Fund. The Current Post-Effective Amendment reflects these comments.
As Ms. Russell has discussed with Mr. DiStefano, as permitted by Rule 481, the Registrant intends to use the Prospectus and SAI before the proposed effective date of the Registration Statement. The Current Post-Effective Amendment filing was made so that the Prospectus and SAI used before the effective date of the Registration Statement would reflect the Commission's comments. A filing under Rule 485(a)(2) of the General Rules will generally become effective on the 75th day after filing. As noted above, however, the Commission has previously commented on the Prospectus and SAI for the Fund, the Registrant has responded to such comments, and they are reflected in the Current Post-Effective Amendment. Additionally, Rule 485(a)(3) provides that the Commission may declare an amendment filed under Rule 485(a) effective on an earlier date.
We appreciate your consideration of this request and, in light of the circumstances described above, believe that it is consistent with the purposes of the acceleration provisions under the General Rules.
Please call Suzanne Russell of Chapman and Cutler LLP at (312) 845-3446 with any comments or questions concerning this request.
Very truly yours,
The Integrity Funds
By: /s/ Shannon D. Radke
Shannon D. Radke
President
Integrity Funds Distributor, LLC
By: /s/ Shannon D. Radke
Shannon D. Radke
President