May 8, 2009
Ms. Patsy Mengiste
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
ATTN.: Document Control - EDGAR
RE: RIVERSOURCE DIVERSIFIED INCOME SERIES, INC. (FILE NOS. 002-51586 /
811-02503)
N-CSR for the annual report for the period ended Aug. 31, 2008 for
RiverSource Diversified Bond Fund
RIVERSOURCE GLOBAL SERIES, INC. (FILE NOS. 033-25824 / 811-05696)
N-CSR for the annual reports for the period ended Oct. 31, 2008 for the
following series:
RiverSource Global Technology Fund, Threadneedle Emerging Markets
Fund and Threadneedle Global Equity Fund
RIVERSOURCE GOVERNMENT INCOME SERIES, INC. (FILE NOS. 002-96512 /
811-04260)
N-CSR for the annual report for the period ended May 31, 2008 for
RiverSource Short Duration U.S. Government Fund
RIVERSOURCE HIGH YIELD INCOME SERIES, INC. (FILE NOS. 002-86637 /
811-03848)
N-CSR for the annual report for the period ended May 31, 2008 for
RiverSource High Yield Bond Fund
RIVERSOURCE INTERNATIONAL MANAGERS SERIES, INC. (FILE NOS. 333-64010 /
811-10427)
N-CSR for the annual report for the period ended Oct. 31, 2008 for
RiverSource Partners International Select Growth Fund
RIVERSOURCE INVESTMENT SERIES, INC. (FILE NOS. 002-11328 / 811-00054)
N-CSR for the annual report for the period ended Sept. 30, 2008 for
RiverSource Balanced Fund
RIVERSOURCE LARGE CAP SERIES, INC. (FILE NOS. 002-38355 / 811-02111)
N-CSR for the annual reports for the period ended July 31, 2008
for the following series:
RiverSource Growth Fund, RiverSource Disciplined Equity Fund,
RiverSource Large Cap Equity Fund and RiverSource Large Cap Value
Fund
RIVERSOURCE MARKET ADVANTAGE SERIES, INC. (FILE NOS. 033-30770 / 811-05897)
N-CSR for the annual report for the period ended Jan. 31, 2009 for the
following series:
RiverSource Portfolio Builder Conservative Fund, RiverSource
Portfolio Builder Moderate Conservative Fund, RiverSource Portfolio
Builder Moderate Fund, RiverSource Portfolio Builder Moderate
Aggressive Fund, RiverSource Portfolio Builder Aggressive Fund and
RiverSource Portfolio Builder Total Equity Fund
RIVERSOURCE STRATEGY SERIES, INC. (FILE NOS. 002-89288 / 811-03956)
N-CSR for the annual reports for the period ended March 31, 2008 for the
following series:
RiverSource Equity Value Fund and RiverSource Small Cap Advantage
Fund
SELIGMAN ASSET ALLOCATION SERIES, INC. (FILE NOS. 333-85111/ 811-09545)
N-CSR for the annual report for the period ended Dec. 31, 2008 for the
following series:
Seligman Asset Allocation Aggressive Growth Fund, Seligman Asset
Allocation Balanced Fund, Seligman Asset Allocation Growth Fund and
Seligman Asset Allocation Moderate Growth Fund
SELIGMAN COMMON STOCK FUND, INC. (FILE NOS. 002-10835 / 811-00234)
N-CSR for the annual report for the period ended Dec. 31, 2008 for
Seligman Common Stock Fund, Inc.
SELIGMAN CORE FIXED INCOME FUND, INC. (FILE NOS. 333-63546 / 811-10423)
N-CSR for the annual report for the period ended Sept. 30, 2008 for
Seligman Core Fixed Income Fund, Inc.
SELIGMAN GLOBAL FUND SERIES, INC. (FILE NOS. 033-44186 / 811-06485)
N-CSR for the annual report for the period ended Oct. 31, 2008 for the
following series:
Seligman Emerging Markets Fund, Seligman Global Growth Fund, Seligman
Global Smaller Companies Fund, Seligman Global Technology Fund and
Seligman International Growth Fund
SELIGMAN GROWTH FUND, INC. (FILE NOS. 002-10836 / 811-00229)
N-CSR for the annual report for the period ended Dec. 31, 2008 for
Seligman Growth Fund, Inc.
SELIGMAN HIGH INCOME FUND SERIES (FILE NOS. 002-93076 / 811-04103)
N-CSR for the annual reports for the period ended Dec. 31, 2008 for the
following series:
Seligman High-Yield Fund and Seligman U.S. Government Securities Fund
SELIGMAN INCOME AND GROWTH FUND, INC. (FILE NOS. 002-10837 / 811-00525)
N-CSR for the annual report for the period ended Dec. 31, 2008 for
Seligman Income and Growth Fund, Inc.
SELIGMAN MUNICIPAL FUND SERIES, INC. (FILE NOS. 002-86008 / 811-03828)
N-CSR for the annual report for the period ended Sept. 30, 2008 for the
following series:
Seligman Colorado Fund, Seligman Georgia Fund, Seligman Louisiana
Fund, Seligman Maryland Fund, Seligman Massachusetts Fund, Seligman
Michigan Fund, Seligman Minnesota Fund, Seligman Missouri Fund,
Seligman National Fund, Seligman New York Fund, Seligman Ohio Fund,
Seligman Oregon Fund and Seligman South Carolina Fund
SELIGMAN MUNICIPAL SERIES TRUST (FILE NOS. 002-92569 / 811-04250)
SELIGMAN NEW JERSEY MUNICIPAL FUND, INC. (FILE NOS. 033-13401 / 811-05126)
SELIGMAN PENNSYLVANIA MUNICIPAL FUND SERIES (FILE NOS. 033-05793 /
811-04666)
N-CSR for the annual report for the period ended Sept. 30, 2008 for the
following funds:
Seligman Municipal Series Trust
California High-Yield Fund, California Quality Fund, Florida Fund
and North Carolina Fund
Seligman New Jersey Municipal Fund, Inc.
Seligman Pennsylvania Municipal Fund Series
SELIGMAN VALUE FUND SERIES, INC. (FILE NOS. 333-20621 / 811-08031)
N-CSR for the annual report for the period ended Dec. 31, 2008 for the
following series:
Seligman Large-Cap Value Fund and Seligman Smaller-Cap Value Fund
Dear Ms. Mengiste:
This letter responds to your comments received by telephone on April 3, 2009 for
the above-referenced Funds' annual reports filed on Form N-CSR for the periods
indicated.
COMMENT 1: For the Seligman Municipal Funds' shareholder reports, please provide
the management's discussion of fund performance (MDFP) separately for each Fund.
RESPONSE: The Seligman Municipal Funds are generally managed in a
consistent manner with regard to quality, duration and type of bonds. Where
differences exist, they are commented upon if they have a significant
effect on performance. For example, the last paragraph of the MDFP for the
report including Seligman Municipal Series Trust notes the impact on
various funds of their relative holdings of pollution control/industrial
development bonds. Future reports will provide additional, separate
commentary on specific Funds, as appropriate.
COMMENT 2: For applicable Fund shareholder reports, please revise the graph
depicting the Fund's long-term performance to improve the ability to distinguish
between the lines representing the Fund and its comparative indices.
RESPONSE: The graph will be redesigned to better distinguish between the
lines representing the Fund and its comparative indices. Design changes may
include one or more of the following: varying line thickness and shading,
minimizing the scale used for the vertical axis and increasing the
frequency of plot points.
COMMENT 3: In general, at fiscal year end or subsequent thereto, have the Funds
experienced any issues with regard to liquidity, valuation, pricing or
redemptions? If so, to what extent?
RESPONSE: During the period, no Fund experienced liquidity issues impacting
its investment operations or its ability to satisfy redemption requests,
and no Fund experienced material pricing or valuation issues. Because of
the volatility of the recent market environment, however, Fund management
has spent increased time and effort to assess the adequacy and sufficiency
of its pricing and valuation procedures.
COMMENT 4: In particular with regards to defaulted portfolio securities, at
fiscal year end or subsequent thereto, have the Funds experienced any material
issues with regard to pricing or liquidity? If so, to what extent?
RESPONSE: During the period, no Fund experienced a material increase in its
exposure to defaulted securities (i.e., no Fund experienced a liquidity
issue as a result of defaulted portfolio securities), and there were no
issues related to the pricing and valuation of such securities. Fund
management continues to adhere to its process for monitoring defaulted
portfolio securities.
COMMENT 5: With regards to securities on loan, please describe the Funds' policy
with regard to the collateral received. Is the collateral invested? Have there
been any problems with pricing of the collateral? Also, please explain whether
the Funds' retain voting authority for securities on loan.
RESPONSE: The RiverSource and Threadneedle Funds have a Securities Lending
Agreement (the Agreement) with JPMorgan Chase Bank, National Association
(JPMorgan) that authorizes JPMorgan as securities lending agent to lend
securities to authorized borrowers on behalf of these Funds. In January
2009, the Board approved this Agreement be adopted for the Seligman Funds.
The Seligman Funds will begin lending following their transition to
JPMorgan as custodian, which is expected to occur in the second or third
quarter 2009. All securities are eligible to be loaned. The Funds retain
discretionary authority to recall securities on loan in order to vote
proxies. The Funds have not had any issues with collateral including the
pricing of collateral. Additional background regarding the securities
lending program is included in the shareholder reports for those Funds that
participate in the securities lending program substantially as follows.
Pursuant to the Agreement, all loaned securities are initially
collateralized in an amount equivalent to 102% (for securities denominated
in U.S. dollars) or 105% (for all other securities) of the value of the
loaned securities, including accrued interest in the case of fixed income
securities. Collateral is maintained over the life of the loan thereafter
in an amount not less than 100% of the market value of loaned securities,
as determined at the close of each business day, except to the extent that
a collateral shortfall is due to a diminution in the market value of
authorized investments in which cash collateral is invested. Any additional
collateral required to maintain those levels due to market fluctuations of
the loaned securities is delivered the following business day. Collateral
is either in the form of cash or U.S. government securities. Cash
collateral received is invested by the lending agent on behalf of the Fund
into authorized investments pursuant to the Agreement. The investments made
with the cash collateral are listed on the Portfolio of Investments and the
value of cash collateral received at period end is disclosed on the
Statement of Assets and Liabilities along with the related obligation to
return the collateral upon return of the securities loaned.
Pursuant to the Agreement, the Fund receives income for lending its
securities either in the form of fees or by earning interest on invested
cash collateral, net of negotiated rebates paid to borrowers and fees paid
to the lending agent for services provided and any other securities lending
expenses. Income earned from securities lending is included in the
Statement of Operations. The Fund also continues to earn interest and
dividends on the securities loaned.
Risks of delay in recovery of securities or even loss of rights in the
securities may occur should the borrower of the securities fail
financially. Risks may also arise to the extent that the value of the
securities loaned increases above the value of the collateral received.
JPMorgan will indemnify the Fund from losses resulting from a borrower's
failure to return a loaned security when due. Such indemnification does not
extend to losses
associated with declines in the value of cash collateral investments. Loans
are subject to termination by the Funds or the borrower at any time, and
are, therefore, not considered to be illiquid investments.
COMMENT 6: To the extent a Fund has a high rate of portfolio turnover, please
highlight it in the MDFP.
RESPONSE: Funds that have experienced a high rate of portfolio turnover
during the last fiscal year will highlight the portfolio turnover in the
MDFP.
COMMENT 7: Please supplementally describe the circumstances under which cash
collateral for securities lending is held with the broker instead of the
custodian.
RESPONSE: JPMorgan acts as the custodian and the securities lending agent
for the RiverSource Funds. As described above in the Response to Comment 5,
it is currently anticipated that the Seligman Funds will begin
participating in JPMorgan's securities lending program following their
transition to JPMorgan as custodian, which is expected to occur in the
second or third quarter 2009. Under the Agreement, JPMorgan holds cash
collateral from securities lending for each Fund in a segregated account
that is separate from each Fund's primary custodial accounts. Cash
collateral is not held by brokers that receive loaned securities.
COMMENT 8: In the Notes to Portfolio of Investments, please include the
percentage of Fund assets held in illiquid securities.
RESPONSE: The percentage of Fund assets held in illiquid securities will be
added to the applicable footnote to the list of Portfolio of Investments.
COMMENT 9: For the Seligman Fund shareholder reports, please explain whether
mortgage dollar rolls are included in Fund borrowing.
RESPONSE: The Seligman Funds account for mortgage dollar rolls as discrete
transactions and record a gain or loss on the sale of the initial security
purchased. The payable for the new security purchased is included within
the line item "Payable for securities purchased" in the Statement of Assets
and Liabilities. They are not treated as borrowings. If the settlement date
of the new security purchased is beyond trade date + 3, the Fund segregates
assets of equal or greater value to cover its purchase obligation.
COMMENT 10: For the RiverSource and Threadneedle Fund shareholder reports,
supplementally explain what "worst of call options" are.
RESPONSE: A worst-of-call option is an over-the-counter options contract
comprised of a basket, or bundle, of call options all with the same
expiration dates but for different underlying assets. On the expiration
date, only the worst performing option (the option where the percentage
move in the price of the underlying asset from trade date to expiration
date is the least) will be exercised.
In connection with the N-CSR filings identified above for the above-referenced
Registrants, each Registrant hereby acknowledges the following:
The disclosures in the filing are the responsibility of the Registrant and
the Registrant is fully responsible for the adequacy or accuracy of the
disclosures in this filing. The Registrant represents to the Commission
that comments made by the Commission, or the staff acting pursuant to
delegated authority, or changes to disclosure in response to staff comments
in the filing reviewed by the staff, do not foreclose the Commission from
taking any action with respect to the filing, and the Registrant represents
that it 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.
If you have any questions, please contact either me at 612-671-4321 or Heidi
Brommer at 612-671-2403.
Sincerely,
/s/ Christopher O. Petersen
-------------------------------------
Christopher O. Petersen
Vice President and Group Counsel
Ameriprise Financial, Inc.