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Capital
World Growth and Income Fund, Inc.
333 South Hope
Street
Los Angeles,
California 90071
Phone (213)
486-9200
Vincent
P. Corti
Secretary
January 27,
2010
Ms. Laura Hatch,
Staff Accountant
U.S. Securities and
Exchange Commission
100 F Street,
NE
Washington, DC
20549
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Re:
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Capital World
Growth and Income Fund, Inc.
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File Nos.
811-07338 and 033-54444
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Dear Ms.
Hatch:
This letter is in
response to oral comments we received from you on January 5, 2010 to the fund’s
Post-Effective Amendment No. 23 to the Registration Statement under the
Securities Act of 1933 and Amendment No. 25 to the Registration Statement under
the Investment Company Act of 1940. We appreciate your prompt
response to the filing.
Our responses to
your comments are set forth below. We will incorporate any changes to the fund’s
Registration Statement in a filing pursuant to Rule 485(b) to be automatically
effective on February 1, 2010.
1. Principal
investment strategies – page 3 of the fund’s prospectus
Comment: Please
state that the fund may invest a portion of its assets in securities of issuers
based outside the U.S., consistent with the fund's name.
Response: We
believe the fund’s disclosure is consistent with its name. The prospectus states
that the fund may invest in companies located around the world and the fund’s
risk disclosure also contains information on the risks of investing in issuers
based outside of the U.S.
2. Principal
investment strategies – page 3 of the fund’s prospectus
Comment: Please
describe the test or factors you consider in determining whether a security is
considered a “foreign security.”
Response: The
following paragraph is included in the Statement of Additional
Information:
“In determining the
domicile of an issuer, the fund's investment adviser will consider the domicile
determination of a leading provider of global indexes, such as Morgan Stanley
Capital International, and may also take into account such factors as where the
company is legally organized and/or maintains principal corporate offices and/or
conducts its principal operations.”
3. Principal
investment strategies – page 3 of the fund’s prospectus
Comment: The
prospectus states that part of the fund’s investment objective is to provide
current income. Please describe how the fund attempts to accomplish
this objective.
Response: We have
updated the language as follows: “The fund invests primarily in
common stocks of well-established companies located around the world, many of
which have the potential to pay dividends.”
4. Principal
investment strategies – page 3 of the fund’s prospectus
Comment: If the
fund may invest in developing markets as a principal investment strategy, please
describe this in the principal investment strategies section.
Response: We have
updated the language as follows: “The fund may also invest in issuers in
developing countries.”
5. Investment
Results – page 5 of the fund’s prospectus
Comment: Please
conform footnote 2 to the requirements of Form N-1A.
Response: We have
updated our disclosure consistent with this comment.
6. Management
– page 6 of the fund’s prospectus
Comment: Please
confirm that the portfolio counselors listed in the table are primarily
responsible for the day to day management of the fund’s portfolio as described
in Form N-1A.
Response: Capital
Research and Management Company uses a system of multiple portfolio counselors
in managing mutual fund assets. Under this approach, the portfolio of a fund is
divided into segments managed by individual counselors who decide how their
respective segments will be invested. Although each individual
counselor may focus on a different aspect of the fund’s investment strategy, the
portfolio counselors listed in the table are primarily responsible for the day
to day management of the fund’s portfolio as described in Form
N-1A.
The changes
described above will also be made to the fund’s retirement plan prospectus, to
the extent the change applies to that document. Thank you for your consideration
of our response to your comments.
If you have any
questions please do not hesitate to contact me at (213) 486-9422 or Katherine
Newhall at (213) 615-0108.
Sincerely,
/s/ Vincent P.
Corti
Vincent P.
Corti
Secretary