MILESFunds, Inc.
January 25, 2016
Chad Eskildsen
Staff Accountant
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549
RE:
Miles Funds, Inc. (“Miles Funds” or the “Fund”)
SEC Registration No. 811-08910
Dear Mr. Eskildsen:
This letter is in response to your email where you provided comments related to your Sarbanes-Oxley review of the referenced Fund’s 3/31/2015 annual report and other EDGAR filings. Your comments and Miles Funds’ responses are set out below:
1. SEC Comment: Form N-Q filings – In the future filings please include a footnote describing the valuation procedures and leveling disclosures (similar to what is in Notes to Financial Statements in 3/31/15 annual report page #9 and #11-12).
Miles Funds Response: Miles Funds will include the requested footnote(s) with the required disclosures in all future Form N-Q filings.
2. SEC Comment: Page 11 – Annual Report – Note 4 – Please include the tax basis of distributions for the two years covered by the statement of changes.
Miles Funds Response: Miles Funds will include the tax basis of distributions for the two years covered by the statement of changes in its next Annual Report.
3. SEC Comment: Page 16 – Expense Example – Please include the actual number of days in the footnote to the table (for example 181/365).
Miles Funds Response: Miles Funds will include the actual number of days in the footnote to the table as noted in all future Financial Statement filings.
I believe the information provided is responsive to your comments and appreciate your assistance in the regard.
Sincerely,
/s/ Gweneth K. Gosselink
Chief Compliance Officer
www.MILES-CAPITAL.com | 1415 28TH STREET, SUITE 200 | WEST DES MOINES, IA 50266 | 800.343.7084
