Van Eck Funds
666 Third Avenue 8th Floor
New York, NY 10017
March 31, 2016
Securities and Exchange Commission
Judiciary Plaza
100 F Street, NE
Washington, D.C. 20549
Attention: Jason Fox
Re: | Van Eck Funds(the “Trust”) |
(File Nos.: 002-97596 and 811 -04297) |
Dear Mr. Fox:
Thank you for your telephonic comments regarding various filings made by the Trust including its annual report on Form N-CSR for the year ended December 31, 2014, relating to certain series of the Trust (each, a “Fund” and, together, the “Funds”). Below, we provide any responses to or any supplemental explanations of such comments, as requested.
Comment 1. | Please remove references to the Multi-Manager Alternatives Fund in the Trust’s EDGAR filing codes. |
Response 1. We will remove such references in future filings. | |
Comment 2. | To the extent any of the Funds engaged in a cross-trade during the period consider disclosing such cross trade in future filings? |
Response 2. We note the staff’s comment. | |
Comment 3. | Please evaluate each Fund’s disclosure in light of sectors identified in the management discussion of financial performance. |
Response 3. We note the staff’s comment and will evaluate such disclosure accordingly. | |
Comment 4. | With respect to the Long/Short Equity Index Fund, please let shareholders know how they can obtain a shareholder report for any ETF that comprises more than 25% of the fund’s assets. |
Response 4. We respectfully acknowledge the staff’s comments. As we are simply investing in these funds and not offering them we are not required to add such disclosure. | |
Comment 5. | Please ensure that the Trust’s Form N-PX is signed by the Trust’s Principal Executive Officer. |
Response 5. We note the staff’s comment and will ensure that the Trust’s Form N-PX is signed by its Principal Executive Officer. |
If you would like to discuss any of these responses in further detail or if you have any questions, please feel free to contact me at (212) 293-2029. Thank you.
Best regards,
/s/Jonathan R. Simon
Jonathan R. Simon