Diana E. McCarthy Partner 215-988-1146 Direct 215-988-2757 Fax Diana.McCarthy@dbr.com |
July 27, 2010
VIA EDGAR
Linda Stirling
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Northern Institutional Funds (Registrant) |
Post-Effective Amendment No. 65
(File Nos. 2-80543 and 811-3605)
Dear Ms. Stirling:
The following responds to the comments we received from you on July 23, 2010, regarding the above-referenced Post-Effective Amendment to Registrants Registration Statement on Form N-1A referenced above (the Post-Effective Amendment). The Post-Effective Amendment was filed to reflect changes to the names and principal investment strategies of the Diversified Growth Portfolio and the Focused Growth Portfolio, which will be renamed the Large Cap Equity Portfolio and the Large Cap Growth Portfolio, respectively (the Portfolios). Our responses (in bold) follow your comments:
Applicable to each of the Portfolios
1. Comment: In order to conform with Instruction 3(e) to Item 3 of Form N-1A, please either obtain an extension of the fee waiver agreement for the Portfolios or remove the fee waiver and corresponding footnote from the tables under the Fees and Expenses of the Portfolio.
Response: Registrant will amend its Advisory Fee Waiver Agreement so that the termination date of the Agreement for these particular Portfolios will be August 1, 2011.
2. Comment: The S&P 500 Index and the Russell 1000 Growth Index do not provide appropriate market capitalization ranges for large cap portfolios such as these.
Response: Registrant respectfully disagrees with this comment. The S&P 500 Index is commonly used in the industry as an index for large capitalization companies and describes itself as focusing on the large cap segment of the market. We are clarifying the disclosure in the prospectus regarding this index to include its focus on large cap stocks. The Russell 1000 Growth Index is the most widely used
Linda Stirling
Page 2
July 27, 2010
index in the industry by large cap growth funds and describes itself as measuring the performance of the large-cap growth segment of the U.S. equity universe. We will also clarify the disclosure in the prospectus about this index to include its focus on large cap stocks.
3. Comment: The discussion under the Principal Investment Strategies section for each Portfolio describing the investment management teams evaluation process in buying and selling securities is generic in nature and needs to be more Portfolio-specific.
Response: Registrant respectfully declines this comment as the above-referenced language was approved in the winter of 2010 and appeared in Registrants prospectus as part of its 2010 annual update.
Applicable to Large Cap Equity Portfolio
4. Comment: Under Principal Risks, please add disclosure about the risks of investing in large cap stocks.
Response: Registrant respectfully declines this comment. The risk disclosure provided states: MARKET RISK is the risk that the value of equity securities owned by the Portfolio may decline, at times sharply and unpredictably, because of economic changes or other events that affect individual issuers or large portions of the market. It includes the risk that a particular style of investing, such as growth or value, may underperform the market generally. Registrant believes that this disclosure is adequate for a large cap mutual fund.
5. Comment: Under Principal Risks, please add disclosure about the risks of using a value style.
Response: Registrant will amend the Market Risk disclosure as follows: It includes the risk that a particular style of investing, such as growth or value, may underperform the market generally.
Applicable to Large Cap Growth Portfolio
6. Comment: Under Principal Risks, please remove Mid Cap Stock Risk because it is not applicable to a large cap fund.
Response: Registrant respectfully declines this comment as the bottom portion of the Russell 1000 Growth Index has mid cap stocks and the Large Cap Growth Portfolio is permitted to invest in mid cap stocks.
Linda Stirling
Page 3
July 27, 2010
7. Comment: Under Principal Risks, please add a Growth Risk.
Response: Registrant notes that the following language is currently located under Market Risk: It includes the risk that a particular style of investing, such as growth, may underperform the market generally. Registrant believes that this disclosure addresses the staffs concerns.
Applicable to Statement of Additional Information
8. Comment: A fundamental policy on senior securities is not included. Please include the next time there is a shareholder vote.
Response: The SAI does disclose a policy on senior securities on page 31 as follows:
In addition, as a matter of fundamental policy, a Portfolio will not issue senior securities to the extent such issuance would violate applicable law.
We thank you for your assistance. If you should have any questions regarding the Registrants responses to your comments, please do not hesitate to contact the undersigned at 215-988-1146.
Sincerely, |
/s/ Diana E. McCarthy |
Diana E. McCarthy |
cc: Craig Carberry, Esq.
NORTHERN INSTITUTIONAL FUNDS
50 South LaSalle Street
Chicago, Illinois 60603
July 27, 2010
VIA EDGAR TRANSMISSION
Linda Stirling
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Northern Institutional Funds |
Post-Effective Amendment No. 65
(File Nos. 2-80543 and 811-3605)
Dear Ms. Stirling:
Pursuant to Rule 461 under the Securities Act of 1933, Northern Institutional Funds (the Trust) hereby requests that the effective date of the above-referenced Post-Effective Amendment to the Trusts Registration Statement on Form N-1A (the Post-Effective Amendment) be accelerated so that the Post-Effective Amendment may be declared effective on July 31, 2010 or as soon thereafter as practicable. The Post-Effective Amendment was filed to reflect changes to the names and principal investment strategies of the Diversified Growth Portfolio and the Focused Growth Portfolio, which will be renamed the Large Cap Equity Portfolio and the Large Cap Growth Portfolio, respectively.
Thank you for your consideration of this request. Should questions arise in conjunction with this request, or if there is any way we can be of assistance in expediting the processing of this request, please call Diana McCarthy, Esq. at (215) 988-1146.
Very truly yours, | ||
NORTHERN INSTITUTIONAL FUNDS | ||
By: | /s/ Owen T. Meacham | |
Owen T. Meacham | ||
Assistant Secretary |
NORTHERN FUNDS DISTRIBUTORS, LLC
Three Canal Plaza
Suite 100
Portland, Maine 04101
July 27, 2010
VIA EDGAR TRANSMISSION
Linda Stirling
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Northern Institutional Funds |
Post-Effective Amendment No. 65
(File Nos. 2-80543 and 811-3605)
Dear Ms. Stirling:
Pursuant to Rule 461 under the Securities Act of 1933, Northern Funds Distributors, LLC, principal underwriter to Northern Institutional Funds (the Trust), hereby requests that the effective date of the above-referenced Post-Effective Amendment to the Trusts Registration Statement on Form N-1A (the Post-Effective Amendment) be accelerated so that the Post-Effective Amendment may be declared effective on July 31, 2010 or as soon thereafter as practicable. The Post-Effective Amendment was filed to reflect changes to the names and principal investment strategies of the Diversified Growth Portfolio and the Focused Growth Portfolio, which will be renamed the Large Cap Equity Portfolio and the Large Cap Growth Portfolio, respectively.
Thank you for your consideration of this request. Should questions arise in conjunction with this request, or if there is any way we can be of assistance in expediting the processing of this request, please call Diana McCarthy, Esq. at (215) 988-1146.
Very truly yours, | ||
NORTHERN FUNDS DISTRIBUTORS, LLC | ||
By: | /s/ Paul Hahesy | |
Paul Hahesy | ||
Chief Compliance Officer |