CORRESPONDENCE FILING
December 22, 2014
Mr. Jeff Long
SEC Financial Reporting
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Re:
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N-CSR SOX Review
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Shelton Funds for 8/31/2014
Shelton Greater China Fund 12/31/2013
The following responses are provided in follow-up to the 3-year SOX review conducted on the referenced Funds.
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1.
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California Tax Free Money Market Fund and the California Insured Intermediate Fund have been deactivated on EDGAR.
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2.
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Fee tables will conform to N-1A requirements when restating expenses.
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3.
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Trustee fees will be disclosed in a separate line in the Statement of Assets and Liabilities.
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4.
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The Statement of Assets and Liabilities for other accrued expenses representing 5% or more will disclosed as a separate item.
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5.
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Shelton Greater China Fund Notes to Financial Statements will contain a chart reflecting the voluntary expense waiver amounts and the recoupment amount by year of expiration for reimbursed expenses going forward.
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6.
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Fidelity bond filings for the Funds will include a copy of the board resolution authorizing payment of the joint bond.
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7.
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Your comment concerning MD&A discussions is under review.
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Sincerely,
/s/ Teresa Axelson
Teresa Axelson, Chief Compliance Officer
Shelton Capital Management|1050 17th Street, Suite 1710|Denver, Colorado 80265-2077
taxelson@sheltoncap.com| 800-955-9988| Direct 415-625-4911