First Focus Funds Corresp
May 28, 2008
Via Federal Express
Patricia Williams
Division of Investment Management
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: First Focus Funds, File Nos. 033-85982: 811-8846
Dear Mrs Williams:
Our response to your comments regarding the first Focus Funds 485(a) filing on February 20,
2008 are as follows:
Prospectus
Short/Intermediate Bond Fund
1. Comment:
Because the Fund may invest up to 20% of its assets in fixed-income securities rated below
investment grade, disclosure describing Junk Bond Risk should be added
Response:
We accepted this comment entirely.
2. Comment:
The description of Commercial mortgage-backed risks should include language describing the
risks associated with investing in subprime mortgages.
Response:
We accepted this comment entirely.
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First Focus Funds, File Nos. 033-85982: 811-8846 May 28, 2008
Income Fund
3. Comment:
Because this Fund is called an Income Fund the primary objective should be the generation of
income. Currently, the Funds objective is to maximize total returns in a manner consistent with
the generation of current income and the preservation of capital.
Response:
The Funds investment objective has not changed since its inception in March 2001. Further,
the Funds investment objective is a fundamental policy and may not be changed without a vote of
the holders of a majority of such Funds outstanding Shares. Thus, we respectfully decline this
comment.
4. Comment:
Because the Fund may invest up to 20% of its assets in fixed-income securities rated below
investment grade, disclosure describing Junk Bond Risk should be added
Response:
We accepted this comment entirely.
5. Comment:
The description of Commercial mortgage-backed risks should include language describing the
risks associated with investing in subprime mortgages.
Response:
We accepted this comment entirely.
6. Comment:
The bar chart reflects the performance of the Income Funds predecessor common trust fund for
all periods prior to March 9, 2001. Please state whether the performance for the period prior to
March 9, 2001 was adjusted for Fund expenses.
Response:
The current disclosure states, The bar chart above includes information regarding the common
trust funds operations for periods before March 9, 2001, as adjusted to reflect the higher
expenses (before any waivers or reimbursements) incurred by the Fund. Since this disclosure
addresses the issue, we respectfully decline the comment.
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First Focus Funds, File Nos. 033-85982: 811-8846 May 28, 2008
Balance Fund
7. Comment:
Expand the description of Interest rate risk to include the effects of maturity.
Response:
The following will be added to the end of the Interest rate risk disclosure:
The value of securities with longer maturities may fluctuate more in response to
interest rate changes than securities with shorter maturities.
Small Company Fund
8. Comment:
Since the Fund invests at least 80% of its assets in securities of companies with small market
capitalizations, it is not necessary to include a description of the risks associated with
investing in Mid-cap stocks in the Principal Risks section. Thus, that risk disclosure should be
disclosed.
Response:
The Mid-cap stocks risk disclosure has been deleted.
International Equity Fund
9. Comment:
In the Principal Investments section, explain how investments will be diversified among a
number of different countries.
Response:
The current disclosure states that the Fund invests in non-U.S. and non-Canadian issuers.
While the Fund is typically invested in issuers from numerous different countries, adding such
specificity would limit the advisers flexibility and possibly impair his duties. Thus, we
respectfully decline this comment.
10. Comment:
Under the performance bar chart, provide a Worst Quarter of performance from the period
represented on the bar chart. Currently, the first year represented n the bar chart is 2003, but
the worst quarter is the quarter ended September 30, 2003
Response:
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First Focus Funds, File Nos. 033-85982: 811-8846 May 28, 2008
We accepted this comment entirely.
Management of the Company
11. Comment:
Clearly state each Portfolio Managers length of service and each Portfolio Managers
respective role on the management team.
Response:
We accept this comment and the disclosure has been amended to more clearly describe each
portfolio managers respective duties and responsibilities.
Service Plan/Expense Tables
12. Comment:
The 0.25% fee described in this section should be broken out as a separate line item in each
Funds expense table per Item 3, Instruction 3.b. in Form N-1A.
Response:
This fee pertains to an administrative function and is detailed in a footnote to the expense
table. Thus, we respectfully decline this comment.
Statement of Additional Information
13. Comment:
Please state if, and to what extent, the International Fund may invest in commodities.
Response:
We accept this comment entirely.
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First Focus Funds, File Nos. 033-85982: 811-8846 May 28, 2008
First Focus Funds will not assert the affirmative action by the SEC to declare its
registration statement effective as a defense in any subsequent action under the federal securities
laws brought by the SEC or any other party. Should you have any questions or comments regarding
the above, please phone me at (617) 824-1312.
Sincerely,
\s\ Patrick J. Keniston
Patrick J. Keniston
Vice President, Citi Fund Services