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AMERICA · ASIA PACIFIC · EUROPE |
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June 12, 2023
John Kernan
Staff Accountant
U.S. Securities and Exchange Commission
Division of Investment Management, Office of the Chief Accountant
100 F. Street, N.E.
Washington, DC 20549
Re: First Eagle Funds (the “Trust” and each series of the Trust, collectively, the “Funds”)
File Nos.: 033-63560 and 811-7762
Dear Mr. Kernan:
Thank you for your comment regarding the Annual Report on Form N-CSR of the Funds, filed with the Securities and Exchange Commission on January 5, 2023. This letter responds to your comment, which you provided to us by telephone on May 11, 2023.
| 1. | COMMENT: The Management’s Discussion of Funds’ Performance (MDFP) section should be enhanced to include a broader discussion of the factors that materially affected performance during the most recent fiscal year, specifically the relevant market factors and investment strategies and techniques used by the Funds’ investment adviser. See Item 27(b)(7) of Form N-1A. The Staff notes that the MDFP focuses on comparative performance and stock and asset class selection in the form of the largest contributors and detractors to performance while market factors and investment strategies and techniques are addressed in the letter from the President. Please explain how the Funds will address the Form requirements. |
RESPONSE: The Funds will incorporate the Staff’s comments in future Annual Reports to shareholders.
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Should you have any follow-up questions concerning this letter, please do not hesitate to contact me at (212) 839-8679.
Sidley Austin (NY) LLP is a Delaware limited liability partnership doing business as Sidley Austin LLP and practicing in affiliation with other Sidley Austin partnerships.
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Sincerely,
/s/ Matthew Kutner
Matthew J. Kutner (as Attorney for the Funds)
cc:
Sheelyn Michael, Deputy General Counsel, First Eagle Investment Management, LLC
Nathan J. Greene, Sidley Austin LLP