0000935069-06-002289.txt : 20120823 0000935069-06-002289.hdr.sgml : 20120823 20060825143916 ACCESSION NUMBER: 0000935069-06-002289 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060825 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RBB FUND INC CENTRAL INDEX KEY: 0000831114 IRS NUMBER: 510312196 STATE OF INCORPORATION: MD FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 400 BELLEVUE PKWY STE 100 CITY: WILMINGTON STATE: DE ZIP: 19809 BUSINESS PHONE: 3027911700 MAIL ADDRESS: STREET 1: 400 BELLEVUE PKWY STREET 2: SUITE 152 CITY: WILMINGTON STATE: DE ZIP: 19809 FORMER COMPANY: FORMER CONFORMED NAME: FUND INC /DE/ DATE OF NAME CHANGE: 19600201 CORRESP 1 filename1.txt Drinker Biddle & Reath LLP One Logan Square 18th and Cherry Streets Philadelphia, Pennsylvania 19103-6996 215-988-2700 Fax: 215-988-2757 WWW.DRINKERBIDDLE.COM August 25, 2006 VIA EDGAR TRANSMISSION Mr. Vincent J. Di Stefano, Jr. Securities and Exchange Commission Judiciary Plaza 100 F. Street, NE Washington, DC 20549 RE: PRELIMINARY PROXY MATERIALS FOR THE MONEY MARKET PORTFOLIO OF THE RBB FUND, INC. (THE "COMPANY") - REGISTRATION NOS. 33-2087/811-5518 Dear Mr. Di Stefano, The purpose of this letter is to respond to your comments on the preliminary proxy materials filed on August 14, 2006 in connection with the Special Meeting of Shareholders of the Company's Money Market Portfolio, (the "Fund"). Included below is a summary of each of the comments and the Company's responses. PROXY STATEMENT COMMENTS 1. COMMENT: Please confirm that the Fund is not changing its current structure to a manager of managers structure. If the Fund was to change its structure to manager of managers, the Board must seek a vote on both the Investment Advisory and Administration Agreement and the Delegation Agreement. RESPONSE: The Fund is not changing its current structure to a manager of managers structure. The Delegation Agreement pertains to certain administrative services that the Adviser is permitted to delegate pursuant to the terms of the Investment Advisory and Administration Agreement. No advisory services are being delegated pursuant to the Delegation Agreement. 2. COMMENT: Does the Fund engage in transactions with affiliated brokers? RESPONSE: The Fund is a money market fund and does not engage in transactions with affiliated brokers. If you would like to further discuss any of the Company's responses, please call me at (215) 988-1105. Sincerely yours, /s/ Alexandra Kane ------------------ Alexandra Kane