0001450789-09-000231.txt : 20120523 0001450789-09-000231.hdr.sgml : 20120523 20090925171612 ACCESSION NUMBER: 0001450789-09-000231 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20090925 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP EQUITY FUNDS II CENTRAL INDEX KEY: 0000027574 IRS NUMBER: 232448660 FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP EQUITY FUNDS II INC DATE OF NAME CHANGE: 19970730 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP DECATUR FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: DECATUR FUND INC DATE OF NAME CHANGE: 19880808 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP EQUITY FUNDS I CENTRAL INDEX KEY: 0000027801 IRS NUMBER: 261651457 FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP EQUITY FUNDS I INC DATE OF NAME CHANGE: 19970604 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP DELAWARE FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE FUND INC DATE OF NAME CHANGE: 19880718 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP INCOME FUNDS CENTRAL INDEX KEY: 0000027825 IRS NUMBER: 232869117 FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP INCOME FUNDS INC DATE OF NAME CHANGE: 19961202 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP DELCHESTER HIGH YIELD BOND FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: DELCHESTER BOND FUND INC DATE OF NAME CHANGE: 19880718 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP EQUITY FUNDS III CENTRAL INDEX KEY: 0000027937 IRS NUMBER: 510106828 STATE OF INCORPORATION: DE FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP EQUITY FUNDS III INC DATE OF NAME CHANGE: 19970909 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP TREND FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: DELTA TREND FUND INC DATE OF NAME CHANGE: 19880630 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP STATE TAX-FREE INCOME TRUST CENTRAL INDEX KEY: 0000201670 IRS NUMBER: 232021993 STATE OF INCORPORATION: DE FISCAL YEAR END: 0228 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18002552139 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP STATE TAX FREE INCOME TRUST/PA/ DATE OF NAME CHANGE: 19980423 FORMER COMPANY: FORMER CONFORMED NAME: DMC TAX FREE INCOME TRUST PA DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP CASH RESERVE CENTRAL INDEX KEY: 0000230173 IRS NUMBER: 232059574 STATE OF INCORPORATION: DE FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP CASH RESERVE /DE/ DATE OF NAME CHANGE: 20000526 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP CASH RESERVE INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP CASH RESERVE DATE OF NAME CHANGE: 19920527 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP TAX FREE MONEY FUND CENTRAL INDEX KEY: 0000320572 IRS NUMBER: 232151642 STATE OF INCORPORATION: DE FISCAL YEAR END: 0430 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP TAX FREE MONEY FUND INC / DATE OF NAME CHANGE: 19930708 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP TAX FREE MONEY FUND INC DATE OF NAME CHANGE: 19921008 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE TAX FREE MONEY FUND INC DATE OF NAME CHANGE: 19880710 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP LIMITED-TERM GOVERNMENT FUNDS CENTRAL INDEX KEY: 0000357059 IRS NUMBER: 232448704 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP LIMITED TERM GOVERNMENT FUNDS DATE OF NAME CHANGE: 19991223 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP LIMITED TERM GOVERNMENT FUNDS INC DATE OF NAME CHANGE: 19950828 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP TREASURY RESERVES INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP TAX FREE FUND CENTRAL INDEX KEY: 0000728352 IRS NUMBER: 232448684 FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP TAX FREE FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: DMC TAX FREE INCOME USA INC DATE OF NAME CHANGE: 19890904 FORMER COMPANY: FORMER CONFORMED NAME: DMC TAX FREE BOND FUND INC DATE OF NAME CHANGE: 19831122 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VOYAGEUR TAX FREE FUNDS CENTRAL INDEX KEY: 0000733362 IRS NUMBER: 411473323 FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR TAX FREE FUNDS INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR MINNESOTA TAX FREE FUNDS INC DATE OF NAME CHANGE: 19910226 FORMER COMPANY: FORMER CONFORMED NAME: DOUBLE EXEMPT FLEX FUND INC DATE OF NAME CHANGE: 19900131 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VOYAGEUR MUTUAL FUNDS III CENTRAL INDEX KEY: 0000763749 IRS NUMBER: 411777915 STATE OF INCORPORATION: DE FISCAL YEAR END: 0430 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR MUTUAL FUNDS III /MN/ DATE OF NAME CHANGE: 20020625 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR MUTUAL FUNDS III INC /MN/ DATE OF NAME CHANGE: 19940318 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR GROWTH STOCK FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP GOVERNMENT FUND CENTRAL INDEX KEY: 0000769220 IRS NUMBER: 232448685 FISCAL YEAR END: 0731 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP GOVERNMENT FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VOYAGEUR INTERMEDIATE TAX FREE FUNDS CENTRAL INDEX KEY: 0000773675 IRS NUMBER: 411522882 FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR INTERMEDIATE TAX FREE FUNDS INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR MINNESOTA INTERMEDIATE TAX FREE FUNDS INC DATE OF NAME CHANGE: 19920305 FORMER COMPANY: FORMER CONFORMED NAME: DOUBLE EXEMPT CAPITAL CONSERVATION FUND INC DATE OF NAME CHANGE: 19900131 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP EQUITY FUNDS IV CENTRAL INDEX KEY: 0000778108 IRS NUMBER: 232369628 FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP EQUITY FUNDS IV INC DATE OF NAME CHANGE: 19970128 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP DELCAP FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: DELCAP FUND INC DATE OF NAME CHANGE: 19880929 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VOYAGEUR INSURED FUNDS CENTRAL INDEX KEY: 0000809064 IRS NUMBER: 411686735 FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR INSURED FUNDS INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR MINNESOTA INSURED FUNDS INC DATE OF NAME CHANGE: 19910926 FORMER COMPANY: FORMER CONFORMED NAME: MINNESOTA INSURED FUND INC DATE OF NAME CHANGE: 19900131 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP EQUITY FUNDS V CENTRAL INDEX KEY: 0000809821 IRS NUMBER: 232450217 STATE OF INCORPORATION: DE FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP EQUITY FUNDS V INC DATE OF NAME CHANGE: 19970128 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP VALUE FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP INSIGHT FUND INC DATE OF NAME CHANGE: 19870621 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VOYAGEUR MUTUAL FUNDS II CENTRAL INDEX KEY: 0000809872 IRS NUMBER: 841044878 STATE OF INCORPORATION: DE FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR MUTUAL FUNDS INC-II DATE OF NAME CHANGE: 19940328 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR COLORADO TAX FREE FUND INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: COLORADO DOUBLE TAX EXEMPT FUND INC DATE OF NAME CHANGE: 19900625 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE POOLED TRUST CENTRAL INDEX KEY: 0000875352 IRS NUMBER: 232651511 STATE OF INCORPORATION: DE FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE POOLED TRUST INC DATE OF NAME CHANGE: 19920717 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP GLOBAL & INTERNATIONAL FUNDS CENTRAL INDEX KEY: 0000875610 IRS NUMBER: 232651520 STATE OF INCORPORATION: DE FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP GLOBAL & INTERNATIONAL FUNDS INC DATE OF NAME CHANGE: 19920717 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Delaware Investments National Municipal Income Fund CENTRAL INDEX KEY: 0000895574 IRS NUMBER: 411737161 STATE OF INCORPORATION: DE FISCAL YEAR END: 0330 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE INVESTMENTS FLORIDA INSURED MUNICIPAL INCOME FUND DATE OF NAME CHANGE: 20020327 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR FLORIDA INSURED MUNICIPAL INCOME FUND DATE OF NAME CHANGE: 19930519 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR FLORIDA INSURD MUNICIPAL INCOME FUND DATE OF NAME CHANGE: 19930122 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE INVESTMENTS ARIZONA MUNICIPAL INCOME FUND, INC CENTRAL INDEX KEY: 0000895577 IRS NUMBER: 411737155 STATE OF INCORPORATION: DE FISCAL YEAR END: 0330 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE INVESTMENTS ARIZONA MUNICIPAL INCOME FUND INC DATE OF NAME CHANGE: 20020327 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR ARIZONA MUNICIPAL INCOME FUND INC DATE OF NAME CHANGE: 19930519 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE INVESTMENTS MINNESOTA MUNICIPAL INCOME FUND II, INC CENTRAL INDEX KEY: 0000895658 IRS NUMBER: 411737158 STATE OF INCORPORATION: DE FISCAL YEAR END: 0330 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE INVESTMENTS MINNESOTA MUNICIPAL INCOME FUND II INC DATE OF NAME CHANGE: 20020327 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR MINNESOTA MUNICIPAL INCOME FUND II INC DATE OF NAME CHANGE: 19930519 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE INVESTMENTS DIVIDEND & INCOME FUND, INC CENTRAL INDEX KEY: 0000896923 IRS NUMBER: 232713064 STATE OF INCORPORATION: DE FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE INVESTMENTS DIVIDEND & INCOME FUND INC DATE OF NAME CHANGE: 20020319 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP DIVIDEND & INCOME FUND INC DATE OF NAME CHANGE: 19930714 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VOYAGEUR MUTUAL FUNDS CENTRAL INDEX KEY: 0000906236 IRS NUMBER: 411720518 FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR MUTUAL FUNDS INC DATE OF NAME CHANGE: 19930714 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Delaware Investments Colorado Municipal Income Fund, Inc. CENTRAL INDEX KEY: 0000907573 IRS NUMBER: 411751991 STATE OF INCORPORATION: DE FISCAL YEAR END: 0330 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE INV COLORADO INSURED MUNICIPAL INCOME FUND INC DATE OF NAME CHANGE: 20020327 FORMER COMPANY: FORMER CONFORMED NAME: VOYAGEUR COLORADO INSURED MUNICIPAL INCOME FUND INC DATE OF NAME CHANGE: 19930621 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP ADVISER FUNDS CENTRAL INDEX KEY: 0000910682 IRS NUMBER: 521842569 STATE OF INCORPORATION: DE FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP ADVISER FUNDS INC /MD/ DATE OF NAME CHANGE: 19961202 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP ADVISER FUNDS INC DATE OF NAME CHANGE: 19960508 FORMER COMPANY: FORMER CONFORMED NAME: LINCOLN ADVISOR FUNDS INC DATE OF NAME CHANGE: 19931203 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE INVESTMENTS GLOBAL DIVIDEND & INCOME FUND, INC CENTRAL INDEX KEY: 0000916713 IRS NUMBER: 232753201 STATE OF INCORPORATION: DE FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE INVESTMENTS GLOBAL DIVIDEND & INCOME FUND INC DATE OF NAME CHANGE: 20020327 FORMER COMPANY: FORMER CONFORMED NAME: DELAWARE GROUP GLOBAL DIVIDEND & INCOME FUND INC DATE OF NAME CHANGE: 19931229 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DELAWARE GROUP FOUNDATION FUNDS CENTRAL INDEX KEY: 0001048133 IRS NUMBER: 232943633 STATE OF INCORPORATION: DE FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET ST CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET ST CITY: PHILADELPHIA STATE: PA ZIP: 19103 FILER: COMPANY DATA: COMPANY CONFORMED NAME: OPTIMUM FUND TRUST CENTRAL INDEX KEY: 0001227523 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 800.914.0278 MAIL ADDRESS: STREET 1: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: BOB TRUST DATE OF NAME CHANGE: 20030415 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Delaware Enhanced Global Dividend & Income Fund CENTRAL INDEX KEY: 0001396167 IRS NUMBER: 260161937 FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 BUSINESS PHONE: 18005231918 MAIL ADDRESS: STREET 1: ONE COMMERCE SQUARE STREET 2: 2005 MARKET STREET CITY: PHILADELPHIA STATE: PA ZIP: 19103 FORMER COMPANY: FORMER CONFORMED NAME: Delaware Investments Enhanced Global Dividend & Income Fund DATE OF NAME CHANGE: 20070411 CORRESP 1 filename1.htm superbowlproxy-secresponsele.htm - Generated by SEC Publisher for SEC Filing

STRADLEY RONON STEVENS & YOUNG, LLP
2600 One Commerce Square
Philadelphia, PA 19103
(215) 564-8000

September 25, 2009

VIA EDGAR

Mr. James O’Connor
Division of Investment Management
U.S. Securities and Exchange Commission
100 F St., NE
Washington, DC 20549

             Re:    Delaware Investments Family of Funds; Optimum Fund Trust

Dear Mr. O’Connor:

     This letter responds to the Staff’s comments regarding the several preliminary proxy statement filings (collectively, the “Proxy Statements”) for the registered investment companies listed on the attached Schedule A (the “Registrants”).

     In connection with the responses to the comments below, each Registrant acknowledges the following:

  • that it is responsible for the adequacy and accuracy of the disclosure in its filings;
  • that Staff comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Securities and Exchange Commission (“Commission”) from taking any action with respect to the filing; and
  • that it may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
1. Comment: Provide precedent for contingent approval of advisory agreements only if the transaction is completed.

           Response: Examples of materially similar contingent advisory agreements were used for the transaction described in a definitive proxy statement filed by BlackRock Funds (June 16, 2006), and in a definitive proxy statement filed by Nuveen Equity Premium and Growth Fund (August 27, 2007). In Stradley Ronon’s experience, this is a common and appropriate approach for obtaining approval of new advisory agreements where the assignment termination event for the

 


James O’Connor
September 25, 2009
Page 2

current advisory agreement has not yet taken place, as it promotes continuity of management and helps minimize uncertainty for fund shareholders.

2. Comment: Please confirm that the Registrants or their investment adviser are not required to apply for new exemptive orders because of the transaction.

           Response: We have reviewed Delaware Investments’ outstanding exemptive orders and can confirm that they do not require application for new exemptive orders. Among other reasons, this is because Delaware Management Company will continue to serve as the Registrants’ investment adviser following the transaction.

3. Provide specific Board conclusions with respect to the facts the Board considered under “Board considerations in approving the New Investment Advisory Agreement.”

          Response: The discussion of the Board’s considerations in approving the investment advisory agreements has been substantially revised to include the requested disclosure. Specific conclusions have been added to the sections entitled: “Nature, Extent and Quality of Service,” “Investment Performance,” “Comparative Expenses,” “Management Profitability,” “Economies of Scale,” “Fall-Out Benefits,” “The Transaction Agreement,” and “Board Review of Macquarie Group.” Similar changes have been added to the proxy statement for Optimum Funds Trust and in the additional proposal to approve a new sub-advisory agreement in the proxy statement for Delaware Pooled Trust.

4. Under the discussion of the Board’s consideration of the funds’ investment performance and comparative expenses, state how the funds actually performed and compared.

         Response: The discussion of the Board’s considerations in approving the investment advisory contracts has been substantially revised to include the requested disclosure. Specific performance and expense information was added with respect to the Delaware Investments Family of Funds in the sections entitled “Investment Performance” and “Comparative Expenses.”

          Please do not hesitate to contact me at 215-564-8011 if you have any further questions.

  Very truly yours,

/s/ Michael D. Mabry
Michael D. Mabry

 


James O’Connor
September 25, 2009
Page 3

Schedule A
Registrants

Delaware Group Adviser Funds (File Nos. 033-67490 and 811-07972) 
Delaware Group Cash Reserve (File Nos. 002-60770 and 811-02806) 
Delaware Group Equity Funds I (File Nos. 002-10765 and 811-00249) 
Delaware Group Equity Funds II (File Nos. 002-13017 and 811-00750) 
Delaware Group Equity Funds III (File Nos. 002-28871 and 811-01485) 
Delaware Group Equity Funds IV (File Nos. 033-00442 and 811-04413) 
Delaware Group Equity Funds V (File Nos. 033-11419 and 811-04997) 
Delaware Group Foundation Funds (File Nos. 333-38801 and 811-08457) 
Delaware Group Global & International Funds (File Nos. 033-41034 and 811-06324) 
Delaware Group Government Funds (File Nos. 002-97889 and 811-04304) 
Delaware Group Income Funds (File Nos. 002-37707 and 811-02071) 
Delaware Group Limited-Term Government Funds (File Nos. 002-75526 and 811-03363) 
Delaware Group State Tax-Free Income Trust (File Nos. 002-57791 and 811-02715) 
Delaware Group Tax-Free Fund (File Nos. 002-86606 and 811-03850) 
Delaware Group Tax-Free Money Fund (File Nos. 002-70164 and 811-03120) 
Delaware Investments Dividend and Income Fund, Inc. (File No. 811-07460) 
Delaware Investments Global Dividend and Income Fund, Inc. (File No. 811-08246) 
Delaware Enhanced Global Dividend and Income Fund (File No. 811-22050) 
Delaware Investments Arizona Municipal Income Fund, Inc. (File No. 811-07412) 
Delaware Investments Colorado Municipal Income Fund, Inc. (File No. 811-07810) 
Delaware Investments National Municipal Income Fund (File No. 811-07410) 
Delaware Investments Minnesota Municipal Income Fund II, Inc. (File No. 811-07420) 
Delaware Pooled Trust (File Nos. 033-40991 and 811-06322) 
Optimum Fund Trust (File Nos. 811-21335 and 333-104654) 
Voyageur Insured Funds (File No. 033-11235 and 811-04973) 
Voyageur Intermediate Tax-Free Funds (File Nos. 002-99266 and 811-04973) 
Voyageur Mutual Funds (File Nos. 033-63238 and 811-07742) 
Voyageur Mutual Funds II (File Nos. 033-11495 and 811-04989) 
Voyageur Mutual Funds III (File Nos. 002-95928 and 811-04547) 
Voyageur Tax Free Funds (File Nos. 002-87910 and 811-03910)