0000766351-18-000002.txt : 20180313
0000766351-18-000002.hdr.sgml : 20180313
20180131140947
ACCESSION NUMBER: 0000766351-18-000002
CONFORMED SUBMISSION TYPE: CORRESP
PUBLIC DOCUMENT COUNT: 1
FILED AS OF DATE: 20180131
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Securian Funds Trust
CENTRAL INDEX KEY: 0000766351
IRS NUMBER: 000000000
STATE OF INCORPORATION: MN
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 400 N ROBERT ST
CITY: ST PAUL
STATE: MN
ZIP: 55101
BUSINESS PHONE: 6516656918
MAIL ADDRESS:
STREET 1: 400 ROBERT STREET NORTH
CITY: ST PAUL
STATE: MN
ZIP: 55101-2098
FORMER COMPANY:
FORMER CONFORMED NAME: ADVANTUS SERIES FUND INC
DATE OF NAME CHANGE: 19970609
FORMER COMPANY:
FORMER CONFORMED NAME: MIMLIC SERIES FUND INC
DATE OF NAME CHANGE: 19920703
CORRESP
1
filename1.txt
January 31, 2018
Jeff Long
Staff Accountant
U.S. Securities and Exchange Commission
Division of Investment Management - Office of the Chief Accountant
100 F Street, NE
Washington, DC 20549
Re: Securian Funds Trust - SOX Review SENT VIA EDGAR
File No. 002-96990 and 811-04279
Dear Mr. Long:
This letter responds to the Securities and Exchange Commission Staff comments
received by Securian Funds Trust ("SFT") via telephone on December 27, 2017.
The Staff's comments are set forth below, followed by SFT's response.
Comments
1. SFT should add a sector risk disclosure for Ivy Growth and Small Cap funds
given that it had a concentration in information technology securities of
greater than 25%.
Response:
SFT's registration statement currently provides a sector risk disclosure
for Ivy Growth and Small Cap funds. We believe this disclosure adequately
addresses the Staff's comment.
2. For all SFT funds in the portfolio holdings section of the annual report,
please disclose the dividend rate for preferred stocks to the extent it is
known.
Response:
To extent available, we will provide dividend rates for preferred stocks.
3. For the Government Money Market Fund Net Investment Income Maintenance
Agreement, provide background on the 1.25% waiver threshold and whether it
relates to the actual expense that was in place at the time of the
agreement.
Response:
The purpose of the expense limit is to avoid overburdening shareholders
due to increases in fund operating expenses. The 1.25% expense limit
restricts the investment adviser's ability to recover waived expenses
during any one reporting period and, thus, places a cap on how much
expenses can be increased. The expense limit value of 1.25% was selected
as a reasonable amount and is not necessarily associated with actual
expenses at the time of the agreement.
4. For the expense limitation agreements for the SFT managed volatility
funds, please explain whether the recoupment is tied to the date of the
waiver or fiscal year end.
Response:
The recoupment is tied to the date of the waiver.
Please direct additional questions or comments to me at (651) 665-4145 or
david.dimitri@securian.com.
Very truly yours,
/s/ David M. Dimitri
David M. Dimitri
Assistant General Counsel