Arthur Don
Tel 312.456.8438
Fax 312.456.8435
dona@gtlaw.com
June [__], 2011
PRE-FILING DRAFT VERSION
VIA EDGAR TRANSMISSION
Mr. Ed Bartz
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Ambassador Funds - Securities Act of 1933 (“1933 Act”) File No. 333-36796, Post-Effective Amendment (“PEA”) No. 25, and Investment Company Act of 1940 (“1940 Act”) File No. 811-09941, PEA No. 26
This letter responds to the staff comments related to Ambassador Funds’ (“Ambassador”) PEA No. 19 on Form N-1A, as discussed in the telephone call between you, myself and my colleague, Richard Cutshall, on April 12, 2011. Please note that Ambassador’s PEA No. 25 is being filed through EDGAR with this letter, and that filing reflects your comments to Ambassador’s PEA No. 19.
The purpose of this letter is to confirm the changes made by Ambassador to comply with each of the comments provided by you. To simplify your review, I have listed each of the comments provided by you in a table set forth below. Next to each item listed, I have set forth Ambassador’s response. You will note that in each instance we have complied with or answered the comment, or have made an adjustment to eliminate the concern that led to a comment. In instances where your comment was applicable to more than one fund, I have recorded the comment once with the first fund to which the comment applies and have indicated the comment’s additional applicability.
GREENBERG TRAURIG, LLP n ATTORNEYS AT LAW n WWW.GTLAW.COM
77 West Wacker Drive, Suite 3100 n Chicago, Illinois n Tel 312.456.8400 n Fax 312.456.8435
Mr. Ed Bartz, U.S. Securities and Exchange Commission
June [__], 2011
Page 2
_____________________
Selkirk Core Fund. The use of the term “Core” in this Fund’s name reflects the investment adviser’s belief that the types of investments in which the adviser plans to invest this Fund’s portfolio, namely equity securities of large- and mid-cap U.S. issuers believed by the adviser to be high-quality companies, are the types of investments that should form the nucleus or “core” of any investor’s portfolio.
Limitations on Exposure to Derivative Counterparty Risk. After discussions with the Selkirk Bond Fund’s and Selkirk Short-Term Bond Fund’s portfolio manager, we have been advised that these two Funds are not expected to use options or futures to any significant extent (in fact, they expect that far less than 10 percent of either Fund’s portfolio would be exposed to the use of such derivatives at any time). The Summary and Statutory Prospectuses have consequently been revised to remove references to these strategies and risks, although they have been added to Ambassador’s Statement of Additional Information.
I believe this fully responds to the staff comments that you provided. We will be happy to address promptly any further questions that you may have regarding this filing. You will also note that, as discussed on June 1, 2011, PEA No. 24 extended the requested effective date of this PEA, as permitted by Rule 485(b) under the 1933 Act. We seek an effective date of July 1, 2011, and note that the Board and non-interested Trustees of Ambassador approved the Section 15(c) agreements on June 7, 2011. All other changes contained in PEA No. 25 were made in connection with finalizing certain of the financial data and other previously incomplete information Consequently, based solely upon our review of Ambassador’s PEA No. 25 to be filed herewith, we represent that such PEA does not contain disclosures that would render it ineligible to become effective under paragraph (b) of Rule 485 under the 1933 Act.
In connection with the PEA filings, we note the following on behalf of Ambassador: (1) Ambassador is responsible for the accuracy and adequacy of the disclosures in its filing: (2) Staff comments or changes to disclosure in response to staff comments in the filing reviewed by the staff do not foreclose the U.S. Securities and Exchange Commission from taking any action with respect to the filing; and (3) Ambassador may not assert staff comments as a defense in any proceeding initiated by the U.S. Securities and Exchange Commission under the federal securities laws of the United States. In addition, we are aware that the Division of Enforcement has access to all information we provide to the staff of the Division of Investment Management in its review of Ambassador’s filings or in response to staff comments on Ambassador’s filings.
Questions concerning these materials may be directed to the undersigned at (312) 456-8438, or to my colleague Richard Cutshall, Esq. at (312) 476-5121.
Best regards,
GREENBERG TRAURIG, LLP
By:/s/ Arthur Don
Arthur Don, a Shareholder
cc:
Brian T. Jeffries
Robert S. Bacarella
Maria C. De Nicolo
Richard M. Cutshall
GREENBERG TRAURIG, LLP