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| ngreene@shearman.com (212) 848-4668 | April 10, 2014 |
| Kenneth Ellington U.S. Securities and Exchange Commission Office of Disclosure and Review Division of Investment Management 100 F Street, N.E. Washington D.C. 20549 |
First Eagle Funds (the “Funds” or the “Trust”)
File Nos. 033-63560 and 811-7762
Dear Mr. Ellington:
Thank you for your comments regarding the Trust’s Annual Report, filed as a Form N-CSR on January 8, 2014. This letter responds to your comments, which you provided to us by telephone on March 26, 2014. Below we summarize your comments and our response.
| I. | Performance Data – Graphs Highlighting Growth of an Initial $10,000 Investment |
| 1. | COMMENT -You commented that the performance graphs for the Funds, highlighting growth of an initial $10,000 investment, do not appear to visually show each Fund's respective front-end sales load as required by Instruction 2 of Item 27(b)(7). You asked that we confirm whether or not each Fund’s front-end sales load is included in our calculations. |
RESPONSE: We reviewed the data for each Fund and confirm that each Fund’s front-end sales load is included in our calculations. We also reviewed the graphic presentations and agree that it is not clear that the starting value is below $10,000. Going forward, we will correct the graphs for these Funds so that visually the hypothetical investment appears to start below the $10,000 line where a share class with a front-end sales
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| Kenneth Ellington | |
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load is charted. First Eagle High Yield Fund and First Eagle Fund of America’s Class I and Class Y shares, respectively, do not charge front-end sales loads, and that is reflected in the graphs and data for those Funds.
Should you have any follow-up questions concerning this letter, please do not hesitate to contact me at (212) 848-4668