K&L GatesLLP 1601 K Street NW Washington, DC 20006-1600
T 202.778.9000 www.klgates.com |
March 1, 2013
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: | LKCM Funds |
Pre-Effective Amendment No. 2 to Registration Statement on Form N-14 |
File No. 333-186318 |
Dear Sir or Madam:
On behalf of LKCM Funds (“Registrant”), transmitted herewith for filing is a Pre-Effective Amendment No. 2 to the Registrant’s registration statement on Form N-14 (the “Registration Statement”). The Registration Statement relates to the reorganization of the shares of Armstrong Associates, Inc. (the “Acquired Fund”) into the Institutional Class shares (the “Shares”) of the LKCM Equity Fund (“Acquiring Fund”), a series of the Registrant.
The purpose of this filing is to: (1) respond to comments provided by the staff of the Securities and Exchange Commission; (2) incorporate by reference in the Registration Statement the Acquiring Fund’s Annual Report to Shareholders and the Acquired Fund’s Semi-Annual Report to Shareholders for the period ended December 31, 2012; (3) and make certain additional non-material changes.
If you have any questions or comments concerning the foregoing, please call me at (202) 778-9015.
Very truly yours,
/s/ Kathy K. Ingber
Kathy K. Ingber
Attachments
cc: | Jacob D. Smith |
Luther King Capital Management