ROPKA LAW, L.L.C.
215 Fries Mill Road
Turnersville, New Jersey 08012
(856) 374-1744
(1-866) 272-8505 (Fax)
December 13, 2019
VIA EDGAR
Elena Stojic, Staff Counsel
U.S. Securities and Exchange Commission
Division of Investment Management
Office of Disclosure and Review
100 F Street N.E.
Washington DC 20549
Re:
Archer Funds (“Registrant”)
File Nos. 333-163981; 811-22356
Dear Ms. Stojic:
Kindly accept this letter on behalf of the Archer Investment Series Trust and its separate series the Archer Focus Fund (the “Fund”). Set forth below are the comments that you expressed in our telephone conversation on December 11, 2019 regarding the Registrant’s Post-effective Amendment No. 26 to its Registration Statement filed with the Securities and Exchange Commission (“SEC”) on October 3, 2019 and the responses thereto. Your comments are set forth in italics and are followed by the Registrant’s responses on behalf of its separate series the Archer Focus Fund, which will be reflected in Post-Effective Amendment No. 29 to be filed hereafter. We are accompanying with this letter the pages that reflect the changes for your reference.
The Registrant’s responses are as follows:
1.
Because you have indicated that the Fund will not concentrate its investments, please revise the first bullet point under the heading “Principal Investment Strategies of the Fund” on page 6.
Response: The Registrant has revised the referenced disclosure.
2.
Please ensure that the Fund’s policy regarding concentration is included in the Statement of Additional Information per Form N-1A Item 16(c)(1)(iv).
Response: The Registrant has included its policy on concentration in the Statement of Additional Information.
Thank you for your kind attention to the matter. Should you have any questions, please contact me.
Ms. Elena Stojic
December 13, 2019
Page 2 of 2
Sincerely,
/s/ C. Richard Ropka
C. Richard Ropka, Esq.
CRR/ab
cc: client
Encl(s).