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Principal Funds, Inc. 711 High Street, Des Moines, IA 50392 515 247 5111 tel | |
December 21, 2017
VIA EDGAR
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
RE: Principal Funds, Inc. (the “Registrant”) (CIK 0000898745)
Request for Withdrawal of Post-Effective Amendment
File No. 033-59474, 811-07572
Pursuant to Rule 477 under the Securities Act of 1933 (the “Act”), as amended, the Registrant hereby respectfully requests withdrawal of the following Post-Effective Amendment to the Registrant’s Registration Statement on Form N-1A (the “Amendment”):
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Post Effective Amendment Number | Dated Filed | Submission Type | Accession Number |
1921 | January 30, 2017 | 485APOS | 0000898745-17-000041 |
| 197 | March 30, 2017 | 485BXT | 0000898745-17-000468 |
| 203 | April 27, 2017 | 485BXT | 0000898745-17-000571 |
| 205 | May 25, 2017 | 485BXT | 0000898745-17-000893 |
| 211 | June 22, 2017 | 485BXT | 0000898745-17-000999 |
| 219 | July 20, 2017 | 485BXT | 0000898745-17-001061 |
| 221 | August 17, 2017 | 485BXT | 0000898745-17-001082 |
| 225 | September 14, 2017 | 485BXT | 0000898745-17-001128 |
| 230 | October 12, 2017 | 485BXT | 0000898745-17-001222 |
| 234 | November 9, 2017 | 485BXT | 0000898745-17-001261 |
| 236 | December 7, 2017 | 485BXT | 0000898745-17-001281 |
The Amendment relates to the registration of Class T shares for the Registrant’s Diversified Real Asset Fund, EDGE MidCap Fund, Global Multi-Strategy Fund, Opportunistic Municipal Fund, Real Estate Debt Income Fund, and Small-MidCap Dividend Income Fund (collectively, the “Funds”). The series and class identifiers for the Funds and the Class T shares are as follows:
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| Fund | Series Identifier | Class T Identifier |
| Diversified Real Asset Fund | S000028139 | C000182252 |
| EDGE MidCap Fund | S000049582 | C000182258 |
| Global Multi-Strategy Fund | S000033960 | C000182254 |
| Opportunistic Municipal Fund | S000037379 | C000182256 |
| Real Estate Debt Income Fund | S000047841 | C000182257 |
| Small-MidCap Dividend Income Fund | S000032942 | C000182253 |
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1 This withdrawal does not affect that portion of Post-Effective Amendment No. 192 that relates to the addition of Class T shares to the Registrant’s Blue Chip Fund and the Preferred Securities Fund, the effectiveness of which occurred on June 12, 2017, via Post-Effective Amendment No. 209.
Except as otherwise noted above in relation to specified portions of Post-Effective Amendment No. 192, no securities were sold in connection with the Amendment. The Registrant has determined not to proceed with the offering of Class T shares of the Funds at this time.
If you would like to discuss this withdrawal request in further detail or if you have any questions, please feel free to contact me at 515-235-9328 or Jennifer Block at 515-235-9154.
Regards,
/s/ Adam Shaikh
Adam Shaikh
Counsel
