May 4, 2010 | ||
via EDGAR | ||
John Grzeskiewicz | ||
Division of Investment Management | ||
Securities and Exchange Commission | ||
100 F Street, NE | ||
Washington D.C. 20549 | ||
Re: | Principal Funds, Inc. | |
Registration Statement on Form N-14/A | ||
Pursuant to Securities Act of 1933 | ||
Registration No. 333-165915 | ||
REQUEST FOR ACCELERATION | ||
Dear Mr. Grzeskiewicz, | ||
Pursuant to Rule 461 under the Securities Act of 1933, as amended, Principal Funds, Inc. (the | ||
“Registrant”) and its principal underwriter, Principal Funds Distributor, Inc., hereby request that the | ||
effectiveness of the above-referenced Registration Statement on Form N-14/A be accelerated to May 6, | ||
2010, or as soon as possible thereafter. Based on previous telephone conversations with the staff, we | ||
understand the staff would give favorable consideration to this request. | ||
The Registrant and Principal Funds Distributor, Inc. acknowledge their statutory obligations under | ||
federal securities laws. The Registrant acknowledges that it is responsible for the adequacy and | ||
accuracy of the disclosure in the registration statement and that should the Commission or its staff, acting | ||
pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from | ||
action with respect to the filing. The Registrant acknowledges that the action of the Commission or its | ||
staff, acting pursuant to delegated authority, in accelerating the effective date of the Registration | ||
Statement, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of | ||
disclosures in the registration statement. The Registrant further acknowledges that it may not assert | ||
Commission staff comments, or changes in disclosure in response to the same, as a defense in any | ||
proceeding initiated by the Commission or any person under the federal securities laws. | ||
Please call me at 515-235-9328 if you have any questions. | ||
Sincerely, | ||
/s/ Adam U. Shaikh | /s/ Adam U. Shaikh | |
Adam U. Shaikh | Adam U. Shaikh | |
Assistant Counsel | Counsel | |
Principal Funds, Inc. | Principal Funds Distributor, Inc |
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