Faegre Drinker Biddle & Reath LLP
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www.faegredrinker.com
February 23, 2021
Via Edgar Transmission
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Jeff Long
| RE: | Northern Funds (811-08236) |
Sarbanes-Oxley Review
Dear Mr. Long:
The following responds to the SEC Staff’s comments that you provided by telephone on January 26, 2021 regarding the review of the N-CSR filed by Northern Funds (the “Trust, and each series thereof, a “Fund”) for its fiscal year ended March 31, 2020.
For your convenience, the Staff’s comments are summarized below and each comment is followed by the Trust’s response.
1. Comment: Multi-Manager Global Listed Infrastructure Fund states that it is non-diversified. As of March 31, 2020, the Fund was operating as a diversified fund. If the Multi-Manager Global Listed Infrastructure Fund has been operating as diversified for the last three years, confirm it will receive shareholder approval for the switch to non-diversified status.
Response: The registrant confirms that, if the Multi-Manager Global Listed Infrastructure Fund operates as a diversified fund for a period of three years, the Multi-Manager Global Listed Infrastructure Fund will seek shareholder approval before operating as a non-diversified fund.
| Regards, |
/s/ Andrew E. Seaberg |
| Andrew E. Seaberg |
Copy to: Peter K. Ewing
Jose Del Real
Randal E. Rein
Kevin O’Rourke
Diana E. McCarthy
