January
8, 2009
VIA
EDGAR
Mr. Chad Eskildsen
Securities
and Exchange Commission
Division
of Investment Management
100 F
Street, N.E.
Washington
DC 20549
|
|
Re:
|
Wisconsin
Capital Funds, Inc. (the
"Registrant")
|
1933
Act Reg. No. 33-141917; 1940 Act File No. 811-22045
Response
to Staff Telephone Comments on Registrant’s Annual Report on Form N-CSR for the
period ended March 31, 2008
Dear Mr.
Eskildsen:
On behalf
of our client, Wisconsin Capital Funds, Inc. (the "Registrant"), we are
transmitting for filing via EDGAR this letter as a response to the staff’s
comment, as we understand it, based upon a telephone conversation we had with
the staff on December 22, 2008, on the Registrant’s Annual Report on Form N-CSR
for the period ended March 31, 2008 (the “Annual Report”). All
references to “we” mean the Registrant, and where applicable, each of its mutual
fund series (each a “Fund”, and collectively, the “Funds”).
Set forth
below is a numbered paragraph identifying what we believe the staff’s comment to
be, which is immediately followed by the Registrant’s response.
STAFF
COMMENT AND REGISTRANT RESPONSE
Comment
1. The
staff noted that the Plumb Balanced Fund currently has an investment restriction
that prevents the Fund from purchasing securities of issuers conducting their
principal business activity in the same industry if immediately after such
purchase the value of the Fund's investments in such industry would exceed 25%
of the value of its total assets. The staff also noted that on page
10 of the Funds’ Annual Report, the pie chart shows that at March 31, 2008, the
Plumb Balanced Fund had 27% of its portfolio invested in securities of issuers
in the Financial Sector. The staff inquired if, in light of the fact
that the Plumb Balanced Fund had 27% of its portfolio invested in securities of
issuers in the Financial Sector, the Fund was in compliance with the
aforementioned investment restriction at March 31, 2008.
Response. The Plumb Balanced
Fund was in compliance with the aforementioned investment restriction at March
31, 2008. The relevant restriction on the Funds is contained on
page 16 of the Funds’ Statement of Additional Information, dated August 1,
2008. It states that a Fund may not “[p]urchase the securities of
issuers conducting their principal business activity in the same industry
if immediately after such purchase the value of the Fund's investments in such
industry would exceed 25% of the value of its total assets” (emphasis
added). The Funds’ use the Global Industry Classification Standard
(“GICS”) when determining whether a Fund is in compliance with this industry
investment limitation. As the staff pointed out, page 10 of the
Funds’ Annual Report, the pie chart shows that at March 31, 2008, the Plumb
Balanced Fund had 27% of its portfolio invested in securities of issuers in the
Financial
Sector. Under GICS, the Financial Sector is comprised of 4
industries: Banks, Diversified Financials, Insurance and Real
Estate. Thus, while 27% of the Plumb Balanced Fund’s portfolio at
March 31, 2008 consisted of securities of issuers in the Financial Sector, its
portfolio holdings in issuers of each industry of the Financial Sector did not
exceed 25%.
Mr. Chad Eskildsen
January
8, 2009
Page 2
The Registrant acknowledges and agrees
that it is responsible for the adequacy and accuracy of the disclosures
made in the Annual Report; that the SEC staff comments or the Registrant’s
responses to the SEC staff comments in the filings reviewed by the staff do not
foreclose the SEC from taking any action with respect to the filing; and that
the Registrant may not assert SEC staff comments as a defense in any proceedings
initiated by the SEC or any person under the federal securities laws of the
United States.
If you
have any questions regarding this letter or further comments on the Annual
Report, please contact me at (414) 277-5629 or aketter@quarles.com or Fred Lautz
of this office at (414) 277-5309 or flautz@quarles.com. Thank
you in advance for your prompt attention to this matter.
Very
truly yours,
QUARLES
& BRADY LLP
/s/
Andrew D. Ketter
Andrew D.
Ketter
ADK:aketter