| |
| November 18, 2011 |
| |
| via EDGAR |
| |
| Kieran Brown |
| Christina DiAngelo |
| 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 (Accession No. 0000898745-11-000786) |
| | Pursuant to Securities Act of 1933 |
| | Registration No. 333-178050 |
| | REQUEST FOR ACCELERATION |
| |
| Dear Mr. Brown and Ms. DiAngelo, |
| |
| 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 be accelerated to December 8, |
| 2011, 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, |
