1. | Staff Comment: Please ensure that all of the bracketed information and other incomplete information that appears in the 485(a) Amendment is completed in the Amendment. |
2. | Staff Comment: Please insert the ticker symbol for the new Class Y shares on the front cover of the prospectus and update it on EDGAR when available. |
3. | Staff Comment: Please complete the information in the Fund's fee table and example and provide to the Staff for review prior to the effective date of the Amendment. |
4. | Staff Comment: Footnote ** to the fee table states: "Other expenses for Class Y are estimated amounts for the current fiscal year based on the Other expenses for Class I." Please supplementally explain the basis for estimating fees for the Fund's new Class Y shares. Please note that Instruction 3(d) to Item 3 of Form N-1A sets forth when information in the fee table may be restated, and that new classes do not satisfy the definition of a "New Fund" set forth in Instruction 6 to Item 3 of Form N-1A. |
5. | Staff Comment: Please disclose in Item 4 whether the Fund invests in companies of particular market capitalizations, and, if so, please provide the ranges of such market capitalizations. The Staff notes that the requested disclosure is partially provided in the tenth paragraph in Fund Details—Goal and Approach. |
6. | Staff Comment: The first paragraph states: "To pursue its goals, the fund, under normal circumstances, invests at least 80% of its net assets in the common stocks of companies that, in the opinion of the fund's management, meet traditional investment standards and conduct their business in a manner that contributes to the enhancement of the quality of life in America." Please revise this disclosure to note whether common stock is the only type of stock in which the Fund will invest. Please also disclose the types of investments that comprise the remaining 20% of the Fund's net assets. In addition, please disclose whether the investments that comprise the remaining 20% of the Fund's net assets will be subject to the same "social screening process" disclosed in the first sentence of the sixth paragraph of Fund Details—Goal and Approach. To the extent this additional disclosure affects existing disclosure in Items 4 and 9, please revise those Items accordingly. |
7. | Staff Comment: Please add risk disclosure relating to the Fund's investments in large-cap growth stocks. |
| Large cap stock risk. To the extent the fund invests in large capitalization stocks, the fund may underperform funds that invest primarily in the stocks of lower quality, smaller capitalization companies during periods when the stocks of such companies are in favor. |
| Growth stock risk. Investors often expect growth companies to increase their earnings at a certain rate. If these expectations are not met, investors can punish the stocks inordinately, even if earnings do increase. In addition, growth stocks may lack the dividend yield that may cushion stock prices in market downturns. |
8. | Staff Comment: The first and second sentences of the eighth paragraph state: "If the portfolio managers determine that a company fails to meet the fund's social criteria, the stock will not be purchased, or if it is already owned, it will be sold as soon as reasonably possible, consistent with the best interests of the fund. If the portfolio managers' assessment does not reveal a negative pattern of conduct in these social areas, the company's stock is eligible for purchase or retention." The Staff views this disclosure as relating to, and being a part of, the Fund's principal investment strategy. The Staff also views the scenarios contemplated in this disclosure as probable to occur. Accordingly, please add risk disclosure in Items 4 and 9 (below Social investment risk in each Item) with respect to the above-referenced disclosure. |
| Social investment risk. Socially responsible investment criteria may limit the number of investment opportunities available to the fund, and as a result, at times the fund's returns may be lower than those funds that are not subject to such special investment considerations. If the portfolio managers determine that a company in the fund's portfolio fails to meet the fund's social criteria, the company's stock will be sold as soon as reasonably possible, consistent with the best interests of the fund. |
| Social investment risk. Socially responsible investment criteria may limit the number of investment opportunities available to the fund, and as a result, at times the fund's returns may be lower than those funds that are not subject to such special investment considerations. The fund's portfolio managers are dependent on available information to assist in the social screening process, and, because there are few generally accepted standards to use in evaluation, the process employed for the fund may differ from processes employed for other funds. If the portfolio managers determine that a company in the fund's portfolio fails to meet the fund's social criteria, the company's stock will be sold as soon as reasonably possible, consistent with the best interests of the fund. |
9. | Staff Comment: Please add risk disclosure with respect to the Fund's investment in large-, mid- and small-cap companies. |
| Large cap stock risk. To the extent the fund invests in large capitalization stocks, the fund may underperform funds that invest primarily in the stocks of lower quality, smaller capitalization companies during periods when the stocks of such companies are in favor. |
| Small and midsize company risk. Small and midsize companies carry additional risks because the operating histories of these companies tend to be more limited, their earnings and revenues less predictable (and some companies may be experiencing significant losses), and their share prices more volatile than those of larger, more established companies. These companies may have limited product lines, markets or financial resources, or may depend on a limited management group. Other investments are made in anticipation of future products, services or events whose delay or cancellation could cause the stock price to drop. The shares of smaller companies tend to trade less frequently than those of larger, more established companies, which can adversely affect the pricing of these securities and the fund's ability to sell these securities. Some of the fund's investments will rise and fall based on investor perception rather than economic factors. |
10. | Staff Comment: Item 4(b)(1)(i) of Form N-1A states that "[b]ased on the information given in response to Item 9(c), [the Fund should] summarize the principal risks of investing in the Fund[.]" See also IM Guidance 2014-08. The Staff notes that, with respect to Social investment risk, the disclosure in Items 4 and 9 are currently identical. Accordingly, please revise Social investment risk in Items 4 and 9 so that the disclosure in Item 4 is a summary of the disclosure in Item 9. |
11. | Staff Comment: The fourth sentence of the first paragraph states: "A discussion regarding the basis for the board's approving the fund's management agreement with Dreyfus is available in the fund's semiannual report for the six-month period ended November 30, 2015." Please revise this sentence to refer to the Fund's most recent annual report. See Item 10(a)(1)(iii) of Form N-1A. |
12. | Staff Comment: Please place the SEC file number at the bottom of the page and reduce the font size. Per Item 1(b)(4) of Form N-1A, include "[t]he Fund's Investment Company Act file number on the bottom of the back cover page in type smaller than that generally used in the prospectus (e.g., 8-point modern type)." |
13. | Staff Comment: Please update the chart to provide information on each person who owns of record or is known by the Fund to beneficially own 5% or more of any class of each Fund's outstanding shares as of a specified date no more than 30 days prior to the filing of the relevant Amendment (see Item 18(b) of Form N-1A). |
Shareholder Fees (fees paid directly from your investment)
|
|||||||
Class A
|
Class C
|
Class I
|
Class Y
|
Class Z
|
|||
Maximum sales charge (load) imposed on purchases
(as a percentage of offering price) |
5.75
|
none
|
none
|
none
|
none
|
||
Maximum deferred sales charge (load)
(as a percentage of lower of purchase or sale price) |
none*
|
1.00
|
none
|
none
|
none
|
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
|
||||||
Class A
|
Class C
|
Class I
|
Class Y
|
Class Z
|
||
Management fees
|
.75
|
.75
|
.75
|
.75
|
.75
|
|
Distribution (12b-1) fees
|
none
|
.75
|
none
|
none
|
none
|
|
Other expenses (including shareholder services fees)
|
.48
|
.48
|
.16
|
.13**
|
.28
|
|
Total annual fund operating expenses
|
1.23
|
1.98
|
.91
|
.88
|
1.03
|
1 Year
|
3 Years
|
5 Years
|
10 Years
|
|
Class A
|
$693
|
$943
|
$1,212
|
$1,978
|
Class C
|
$301
|
$621
|
$1,068
|
$2,306
|
Class I
|
$93
|
$290
|
$504
|
$1,120
|
Class Y
|
$90
|
$281
|
$488
|
$1,084
|
Class Z
|
$105
|
$328
|
$569
|
$1,259
|
1 Year
|
3 Years
|
5 Years
|
10 Years
|
|
Class A
|
$693
|
$943
|
$1,212
|
$1,978
|
Class C
|
$201
|
$621
|
$1,068
|
$2,306
|
Class I
|
$93
|
$290
|
$504
|
$1,120
|
Class Y
|
$90
|
$281
|
$488
|
$1,084
|
Class Z
|
$105
|
$328
|
$569
|
$1,259
|