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