WILLKIE FARR & GALLAGHER 787 Seventh Avenue
New York, NY 10019-6099
Tel: 212 728 8000
Fax: 212 728 8111
August 25, 2005
VIA EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Credit Suisse Opportunity Funds (the "Fund")
Files Nos. File Nos. 033-92982 and 811-09054
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Ladies and Gentlemen:
On behalf of the Fund, I hereby transmit for filing under the Securities Act of
1933, as amended (the "Securities Act"), and the Investment Company Act of 1940,
as amended (the "1940 Act"), Post-Effective Amendment No. 26 ("Amendment No.
26") to the Fund's Registration Statement on Form N-1A (the "Registration
Statement") which, pursuant to Section 310 of Regulation S-T, has been tagged to
indicate the changes from Amendment No. 25 to the Fund's Registration Statement
filed with the Securities and Exchange Commission (the "Commission") on April 1,
2005 ("Amendment No. 25").
Amendment No. 26 is marked to show changes in response to the comments of the
Commission's staff (the "Staff") on Amendment No. 25 that were provided by
Christian T. Sandoe of the Staff in a telephone conversation with Albert Cho.
For the convenience of the Staff, the substance of those comments has been set
forth below. The Fund's responses to each comment is set out immediately under
the restated comment. Page references in the Fund's responses are to the Fund's
revised Class A and Class C Prospectus (the "Revised Prospectus") filed as part
of Amendment No. 26. Please note that conforming changes have also been made to
the Fund's Common Class Prospectus, which was initially filed as part of
Amendment No. 25. Various other stylistic and clarifying changes have also been
made in Amendment No. 26.
PROSPECTUS:
1. KEY POINTS - OVERVIEW (P. 3): To the extent possible please reduce the
amount of information in the "Overview" section of the prospectus by either
incorporating that information into the Risk/Return Summary, to the extent
possible, or moving it behind the Risk/Return Summary.
Securities and Exchange Commission
August 25, 2005
Page 2
Response: The "Overview" section has been revised as requested.
2. GOALS AND PRINCIPAL STRATEGIES - PRINCIPAL STRATEGIES (P. 4): Please
provide additional information in the Risk/Return Summary to give investors
a sense as to how much each Fund will invest within categories of
underlying Credit Suisse Funds (e.g., money market, investment grade, high
yield).
Response: In order to address the Staff's comment without adding
redundancies to the prospectus we have added disclosure referring investors
to a chart on page 20 detailing approximately how much of each Fund will be
invested in categories of underlying Credit Suisse Funds such as money
market, investment grade, high yield, large and mid cap, small cap and
international.
3. A WORD ABOUT RISK - PRINCIPAL RISKS (P. 6); RISK FACTORS (P. 31): Please
include the principal risks of the underlying Credit Suisse Funds in the
Risk/Return Summary and Risk Factors section of the prospectus.
Response: We have made the requested change.
4. A WORD ABOUT RISK - CONFLICTS OF INTEREST RISKS (P. 5); RISK FACTORS (P.
31): Please consider whether "conflicts of interest risk" should be
re-classified under "other risk factors."
Response: We have re-classified "conflicts of interest risk" under "other
risk factors."
5. INVESTOR EXPENSES - FEES AND FUND EXPENSES - FOOTNOTE 4 (P. 16): Please
confirm whether the reference to "average daily net assets attributable to
other investments" in the discussion of the management fee calculation
means that the Funds intend to invest in other securities and other
financial instruments in reliance on an exemptive order from the
Commission.
Response: As noted in the prospectus, the Funds intend to seek exemptive
relief (i.e., page 30). The reference to "other investments" relates to the
investments to be made by the Funds in reliance on such order, if obtained.
6. PORTFOLIO MANAGEMENT (P. 31); MEET THE MANAGERS (P. 39): Please provide
the names and biographies of the portfolio managers and confirm that the
reason why this information was not included in the initial filing was that
it was unavailable at the time.
Response: We have provided the requested information. The reason why this
information was not included in the initial filing was that it was
unavailable at the time.
Securities and Exchange Commission
August 25, 2005
Page 3
7. PORTFOLIO MANAGEMENT SAI DISCLOSURE: Provide the portfolio manager
information that was not included in the original filing.
Response: We have provided this requested information.
* * * * * * * * *
We hope the Staff finds this letter and the revisions in Amendment No. 26
responsive to the Staff's comments on Amendment No. 25.
Should members of the Staff have any questions or comments concerning Amendment
No. 26, please call the undersigned or Rose F. DiMartino of this office at (212)
728-8000.
Very truly yours,
/s/ Aaron D. Wasserman
Aaron D. Wasserman
cc: Christian T. Sandoe
Kevin Gao
Rose F. DiMartino
CREDIT SUISSE OPPORTUNITY FUNDS
466 Lexington Avenue
New York, New York 10017
August 25, 2005
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Credit Suisse Opportunity Funds (the "Fund")
Registration Statement on Form N-1A
File Nos. 033-92982 and 811-09054
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Ladies and Gentlemen:
The Fund, on behalf of its series, Credit Suisse Strategic Allocation Fund
- -- Conservative, Credit Suisse Strategic Allocation Fund -- Moderate and Credit
Suisse Strategic Allocation Fund -- Aggressive, hereby requests that the
effective date for Post-Effective Amendment No. 26 to its Registration Statement
on Form N-1A be accelerated so that it will become effective on September 1,
2005.
Very truly yours,
Credit Suisse Opportunity Funds
By: /s/ J. Kevin Gao
----------------------------------
J. Kevin Gao
Vice President and Secretary
CREDIT SUISSE ASSET MANAGEMENT SECURITIES, INC.
466 Lexington Avenue
New York, New York 10017
August 25, 2005
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Credit Suisse Opportunity Funds (the "Fund")
Registration Statement on Form N-1A
Files Nos. File Nos. 033-92982 and 811-09054
---------------------------------------------------------
Ladies and Gentlemen:
Credit Suisse Asset Management Securities, Inc., the principal underwriter
of the proposed public offering of securities of the Fund, on behalf of its
series, Credit Suisse Strategic Allocation Fund -- Conservative, Credit Suisse
Strategic Allocation Fund -- Moderate and Credit Suisse Strategic Allocation
Fund -- Aggressive, hereby joins the Fund in requesting that the effective date
for Post-Effective Amendment No. 26 to the Fund's Registration Statement on Form
N-1A be accelerated so that it will become effective on September 1, 2005.
Very truly yours,
CREDIT SUISSE ASSET MANAGEMENT SECURITIES, INC.
By: /s/ Steven Plump
-----------------------------------------
Steven Plump
President
VIA EDGAR
August 25, 2005
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Credit Suisse Opportunity Funds (the "Fund")
(Securities Act File No. 033-92982;
Investment Company Act File No. 811-09054)
Post-Effective Amendment No. 26 (the "Amendment")
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Ladies and Gentlemen:
This letter is provided to the Securities and Exchange Commission (the
"Commission") in connection with the above-referenced filing, which is being
made today pursuant to Rule 485(a) under the Securities Act of 1933, as amended
(the "1933 Act").
On behalf of the Fund, we hereby acknowledge that the disclosure in the
Amendment is the Fund's responsibility. On behalf of the Fund, we hereby
acknowledge that the staff's review of Post-Effective Amendment No. 25 to the
Fund's Registration Statement, filed on April 1, 2005 pursuant to Rule 485(a)
under the 1933 Act ("Post-Effective Amendment No. 25") does not foreclose the
Commission from taking any action with respect to the filing of the Amendment
and, on behalf of the Fund, we hereby represent that the Fund will not assert
this action as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.
On behalf of the Fund, we further acknowledge that the staff's review of
Post-Effective Amendment No. 25 does not relieve the Fund from its full
responsibility for the adequacy and accuracy of the disclosures in the
Amendment.
Should members of the staff of the Commission have any questions or comments
concerning the Amendment, they should call the undersigned at (212) 875-3927.
Very truly yours,
/s/ J. Kevin Gao
- -------------------
J. Kevin Gao
cc: Christian Sandoe
Rose F. DiMartino, Esq.