[ON CHAPMAN AND CUTLER LLP LETTERHEAD]
June 8, 2018
VIA EDGAR CORRESPONDENCE
Elizabeth Bentzinger
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: |
Nuveen Investment Funds, Inc. | |
File Nos. 033-16905 and 811-05309 |
Dear Ms. Bentzinger:
This letter responds to your comments given during a telephone conversation with our office on June 5, 2018, regarding the registration statement filed on Form N-1A for Nuveen Investment Funds, Inc. (the Trust) with the Securities and Exchange Commission (the Commission) on April 20, 2018, which relates to Nuveen Mid Cap Value Fund (the Fund), a series of the Trust. The prospectus for the Fund will be revised in response to your comments.
GENERAL COMMENT
COMMENT 1
Please provide the ticker symbol for Class R6 shares on the cover pages of the prospectus and statement of additional information and update the series class identifier for Class R6 shares on EDGAR once you obtain it.
RESPONSE TO COMMENT 1
The ticker symbol will be added to the cover pages and will be updated on EDGAR.
PROSPECTUS
COMMENT 2 FUND SUMMARY PRINCIPAL INVESTMENT STRATEGIES
Please update the date and market capitalization range of the Russell Midcap® Index.
RESPONSE TO COMMENT 2
Due to the timing of the annual reconstitution of the Russell Midcap® Index, the market capitalization range as disclosed in the prospectus is current as of the proposed effective date of the prospectus.
COMMENT 3 HOW YOU CAN BUY AND SELL SHARES HOW TO REDUCE YOUR SALES CHARGE
Please confirm supplementally that all of the information regarding sales charge waivers required by Item 12(a)(2) of Form N-1A is described in the prospectus, except for the information required by Items 17(d) and 23(b) of Form N-1A.
RESPONSE TO COMMENT 3
Management confirms that all of the information regarding sales charge waivers required by Item 12(a)(2) of Form N-1A is described in the prospectus, except for the information required by Items 17(d) and 23(b) of Form N-1A.
COMMENT 4 HOW YOU CAN BUY AND SELL SHARES HOW TO REDUCE YOUR SALES CHARGE
Under the CDSC Waivers and Reductions section, please (1) remove the phrase including the following; and (2) for the seventh and eighth bullets, disclose all intermediaries subject to these waivers in the appendix to the prospectus.
RESPONSE TO COMMENT 4
The phrase including the following has been removed from the first sentence under the CDSC Waivers and Reductions section. With regard to the seventh and eighth bullets, the waivers described in the two referenced bullets are available to shareholders through any intermediary under the circumstances described. Because the waivers are not limited to only a certain intermediary or intermediaries, no intermediaries are listed in the appendix to the prospectus with respect to these waivers. Consequently, management respectfully declines to make the requested revision.
COMMENT 5 HOW YOU CAN BUY AND SELL SHARES
Please disclose the information required by Items 12(a) and 12(b) of Form N-1A in one place in the prospectus. See General Instructions C.3(a) to Form N-1A.
RESPONSE TO COMMENT 5
The information required by Items 12(a) and 12(b) of Form N-1A is disclosed in one place under the How You Can Buy and Sell Shares section of the prospectus.
Please call me at (312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.
Sincerely yours, | ||
CHAPMAN AND CUTLER LLP | ||
By: |
/s/ Morrison C. Warren | |
Morrison C. Warren |