CORRESPONDENCE FILING
December 22, 2014
Mr. Jeff Long
SEC Financial Reporting
Re: | N-CSR SOX Review |
Shelton Funds for 8/31/2014
Shelton Greater China Fund 12/31/2013
The following responses are provided in follow-up to the 3-year SOX review conducted on the referenced Funds.
1. | California Tax Free Money Market Fund and the California Insured Intermediate Fund have been deactivated on EDGAR. |
2. | Fee tables will conform to N-1A requirements when restating expenses. |
3. | Trustee fees will be disclosed in a separate line in the Statement of Assets and Liabilities. |
4. | The Statement of Assets and Liabilities for other accrued expenses representing 5% or more will disclosed as a separate item. |
5. | Shelton Greater China Fund Notes to Financial Statements will contain a chart reflecting the voluntary expense waiver amounts and the recoupment amount by year of expiration for reimbursed expenses going forward. |
6. | Fidelity bond filings for the Funds will include a copy of the board resolution authorizing payment of the joint bond. |
7. | Your comment concerning MD&A discussions is under review. |
Sincerely,
/s/ Teresa Axelson
Teresa Axelson, Chief Compliance Officer
Shelton Capital Management|1050 17th Street, Suite 1710|Denver, Colorado 80265-2077
taxelson@sheltoncap.com| 800-955-9988| Direct 415-625-4911