422 Fleming Street, Suite 7
Key West, FL 33040
866-862-1719 (P) & (F)
March 25, 2015
VIA EDGAR
US Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, NW
Washington, DC 20549
| Re: | Timothy Plan Preliminary Proxy Statement |
File Nos. 811-08228 and 333-73248
Ladies and Gentlemen:
On behalf of the Timothy Plan (the “Trust”), transmitted herewith for filing pursuant to Rule 14a-6 under the Securities Exchange Act of 1934 (the “1934 Act”) is Registrant’s Preliminary Proxy Statement which will be used in connection with a special meeting of the shareholders of the Timothy Plan Defensive Strategies Fund (the “Fund”), a separate series of the Trust, to be held on Wednesday, May 13, 2015 (the “Special Meeting”). This Preliminary Proxy Statement consists of a notice of meeting, the proxy statement and form of proxy. This information, including the Proxy Statement, will be mailed to the Trust’s shareholders on or about April , 2015.
The matters to be considered at the Special Meeting will be:
| Proposal 1: | To replace the fundamental investment limitations of the Fund with new updated fundamental investment limitations: | |||
| Proposal 1a: | To amend the fundamental investment limitation with respect to borrowing money and issuing senior securities; | |||
| Proposal 1b: | To amend the fundamental investment limitation with respect to purchasing and selling commodities, and to add a restriction allowing the Fund to purchase and sell gold and other precious metals in amounts not to exceed ten percent (10%) of the Fund’s net assets, in the aggregate; | |||
| Proposal 1c: | To amend the fundamental investment limitation with respect to concentrating investments in a particular industry or group of industries; | |||
| Proposal 1d: | To amend the fundamental investment limitation with respect to investing in real estate; | |||
| Proposal 1e: | To amend the fundamental investment limitation with respect to underwriting securities; | |||
| Proposal 1f: | To amend the fundamental investment limitation with respect to loans: | |||
| Proposal 1g: | To eliminate fundamental investment limitations no longer required by law. | |||
| Proposal 2: | To transact any other business, not currently contemplated, that may properly come before the special meeting of shareholders or any adjournment thereof in the discretion of the proxies or their substitutes. | |||
Please direct all questions or comments regarding the foregoing to me at 866-862-1719. Thank you for your consideration.
Sincerely,
DAVID D. JONES, Esq.