December 9, 2011 |
Via EDGAR |
Kieran Brown |
Christina DiAngelo |
Securities and Exchange Commission |
100 F Street, N.E. |
Washington, D.C. 20549 |
Re: Principal Funds, Inc. |
Registration Statement on Form N-14 |
File No. 333-178050 |
Pre-Effective Amendment No. 1 |
Dear Mr. Brown and Ms. DiAngelo: |
On behalf of Principal Funds, Inc. ("PFI"), we transmit herewith for filing with the Securities and |
Exchange Commission pursuant to Rule 488 under the Securities Act of 1933 (the "Act") PFI's |
registration statement on Form N-14 Pre-Effective Amendment No. 1 under the Act (the |
"Registration Statement"). |
As discussed with the staff, the Registrant intends to file, in a separate correspondence, a request |
for acceleration with respect to the Registration Statement requesting an effective date of |
December 12, 2011, or as soon as possible thereafter. |
We understand that the Registrant is responsible for the accuracy and adequacy of the disclosure |
in the filing and that staff comments or our changes to the disclosure in response to the staff |
comments do not foreclose the Commission from taking any action with respect to the filing. In |
addition, the Registrant may not assert staff comments as a defense in any proceeding initiated by |
the Commission or any person under the federal securities laws of the United States. |
Please call me at 515-235-9328 or Jennifer A. Mills of this office at 515-235-9154 if you have any |
questions or comments. |
Sincerely, |
/s/ Adam U. Shaikh |
Adam U. Shaikh |
Assistant Counsel |
Principal Funds, Inc. |
Enclosures |