DELAWARE GROUP ADVISER FUNDS 2005 Market Street Philadelphia, PA 19103 DELAWARE DISTRIBUTORS, L.P. 2005 Market Street Philadelphia, PA 19103 October 23, 2007 VIA EDGAR Mary Cole, Esq. Senior Counsel Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 RE: Delaware Group Adviser Funds (1933 Act File No.: 333-146274) - Reorganization of Delaware Large Growth Fund With and Into Delaware U.S. Growth Fund - Request for Acceleration Dear Ms. Cole: Attached for filing, pursuant to the Securities Act of 1933, as amended (the "Securities Act"), is Pre-Effective Amendment No. 1 (the "Amended N-14") to the Registration Statement on Form N-14 of Delaware Group Adviser Funds (the "Registrant"), which was initially filed on September 24, 2007 (the "Initial N-14 Filing"). Pursuant to the requirements of Rule 461 of the Securities Act of 1933, as amended, the undersigned officers of the Registrant and Delaware Distributors, L.P., the principal underwriter of the Registrant, respectfully request that the effectiveness of the Registrant's Registration Statement on Form N-14, as amended by the Amended N-14, filed herewith, be accelerated to October 24, 2007. Compared to the Initial N-14 Filing, the Amended N-14 contains financial information and fee tables that have been updated to reflect comments received from you and Ms. Christina DiAngelo. In addition, the Amended N-14 contains updated powers of attorney that were requested by you. It is my understanding that you have previously discussed the possible acceleration of the Amended N-14 with Prufesh R. Modhera of Stradley Ronon Stevens & Young, LLP. In connection with this request for acceleration, the Registrant acknowledges that: (i) the Registrant is responsible for the adequacy and accuracy of the disclosure in the Registrant's filing; (ii) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (iii) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iv) the Registrant may not assert this action as a defense in any proceeding initiated by the Commission under the federal securities laws of the United States. Any questions regarding this request should be directed to Prufesh R. Modhera of Stradley Ronon Stevens & Young, LLP at 202-419-8417. Sincerely yours, /s/ Emilia P. Wang Emilia P. Wang AVP and Assistant Secretary Delaware Group Adviser Funds /s/ Michael E. Dresnin Michael E. Dresnin AVP and Assistant Secretary Delaware Distributors, L.P.
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N-14/A Filing
Delaware Group Adviser Funds N-14/ARegistration statement for investment companies business combination (amended)
Filed: 23 Oct 07, 12:00am