Ms. Sheila Stout
United States Securities and Exchange Commission
Division of Investment Management,
Disclosure Review and Accounting
100 F  Street N.E.
Washington, D.C.  20549

February 13, 2017

The following are responses to questions during a conference
 call with Sheila Stout and
John Ganley on February 7, 2017 regarding Stock Dividend Fund,
 Inc.(811-21576, 333-
115091), and Small Cap Value Fund, Inc.(811-21782, 333-126383).


Responses to Questions/Inquiries in sequence of conference call:

1) In future shareholder letters in NCSR we will enhance our
performance disclosure.

2) In N-1A, Investment Strategy section, we added language that
 more fully describes our
quantitative approach and that our Strategy may result in a
portfolio that has Sector risk.

3) Regarding our 40-17F2 filings
     a)    We will discuss with our Auditor that filings must
 be made in a more timely
	manner than in the past.
     b)    We are not sure why we made a filing on February 12
 when the auditor report
	was dated February 13, but will make certain in the future
 that there is no
	discrepancy.
     c)    We will make certain on future filings that time periods
 match, i.e. we assumed
	that an inspection period of January through August on our
 part was ok to file
	with an auditor report stating April-August the same year,
 given the overlap.  We
	will correct this.

4) In our NCSR and N-1A, our financial tables now reflect 1-5-10
year performance
representation.

5) In our NCSR we have added a Tax Matters section which covers the
 required
disclosures.

6) In our NCSR, item 12, we have added the referenced filed date of
 our Code of Ethics
and also showed how to obtain a copy.

7) In our NCSR, approval of advisory agreement section, we added
details regarding
performance and comparisons discussed by the Board.

8) In our NCSR, item 4, fees paid to the Auditor are now included.

9) In our NCSR, financial highlights table, the expense ratio for
 both Funds is a little high
we think due to very high redemptions during the year, which affected
 the average net
asset value calculation in a slightly negative way versus the norm.
  I.e. the Funds are
relatively small, and the redemptions combined with downward
performance during the
year are meaningful when using month end only numbers for the
calculations.  There
were no expenses charged over the stated amounts that could have cause
 the discrepancy.

10) In our NCSR, Statements and Liabilities, NAV is more prominently
displayed.

11) In Stock Dividend Fund, Inc. NCSR, 2015 Schedule of Investments,
it shows
unaudited, and this is a typo.  The entire NCSR was audited.

12) In our NCSR, regarding approximately $4,500 in ?2016 dividends
 paid in 2015?:  It is
never our goal to over or under distribute actual net income earned
in any given year.  In
2015, the Fund owned a large Canadian bank that went ex-dividend
on 12/31/2015 and
had a pay date of 1/27/2016.  This required us to estimate the U.S
dollar amount we
would receive without knowing the exchange rate or ADR fees that
would apply.  We
over-estimated the expected payment by about $4,500, and thus, in
effect, distributed that
amount too much in 2015.  Thus the footnote of 2016 dividends paid
in 2015.  We do not
expect this to be a problem in the future as the Fund no longer owns
 this position and
generally does not buy foreign ADR stocks.

13) In our NCSR, in Statement of Changes, we have added commentary
that shows the
balance of undistributed investment income at the bottom.

14) In our NCSR, in the Board of Directors section, we have added the
term of one year
and stated that all Directors have been with the Funds since inception.

15) In our 2015 NCSR for Small Cap Value Fund, Inc., in the Financial
Highlights
section, we show a loss of $0.20 from investment income but a
distribution of $0.20.
This was a typo that resulted in an incorrect plug.  The correct number
 should have been
a gain of $0.20 from investment income, and thus the $0.20 distribution,
and a loss of
$8.10 from net realized and unrealized depreciation, instead of a
loss of $7.70.

16) In our 2015 NCSR for Small Cap Value Fund, Inc., the turnover
 stated in the
Financial Highlights at 48.14% is correct.  I am not sure why in the
 shareholder letter we
ended up stating 50.22%.  We will be more careful in the future.

17) In our 2015 NCSR, footnote 8, redemption fees, there was a typo
 on the date, it
should have read 12/31/15 versus 12/31/14.


Thank you for your comments and recommendations.


Please call me if you have any questions regarding the above matters.

Sincerely,



/s/ Steven Adams
Steven Adams
Chief Compliance Officer
214-360-7410

*We are aware that the Fund is responsible for the adequacy and
accuracy of the
disclosure in the filings, and that SEC staff comments or changes
to disclosure in
response to staff comments in the filings reviewed by the staff
 do not foreclose the
Commission from taking any action with respect to the filing, and
 that the Fund may not
assert SEC staff comments as a defense in any proceeding initiated
 by the Commission or
any person under the federal securities laws of the United States.