Daniel A. Peterson
Partner
190 Carondelet Plaza, Suite 600
St. Louis, MO 63105
Direct: 314.345.6246
Fax: 314.480.1505
dan.peterson@huschblackwell.com
August 26, 2014
SEC File Nos. 811-08846 & 33-85982
To the Commission:
On August 26, 2014, the Registrant filed a post-effective amendment to its registration statement under Rule 485(a) of the Securities Act of 1933, as amended (the “Post-Effective Amendment”). This letter is being submitted on behalf of the Registrant in order to identify the undersigned, Daniel A. Peterson, of Husch Blackwell LLP, the Registrant’s outside counsel, as the appropriate party to receive any comments from the Securities and Exchange Commission staff (the “Staff”) in connection with the Post-Effective Amendment.
The changes outlined in the Post-Effective Amendment will be implemented and effective on October 1, 2014. As such, we respectfully request that the Staff declare the Post-Effective Amendment effective as soon as possible, and that you contact the undersigned at your earliest convenience to convey the Staff’s comments in order for the Registrant to respond to such comments in a timely manner such that Tributary can meet the appropriate deadlines to accelerate effectiveness of the Post-Effective Amendment.
I appreciate your support and cooperation in this matter. Please do not hesitate to contact me as counsel for the Fund at (314) 345-6246 with any questions.
/s/ Daniel A. Peterson
Partner
cc: Ms. Brittany Fahrenkrog
Tributary Capital Management
1620 Dodge Street, Stop 1089
Omaha, Nebraska 68197
Ms. Angela Burke
Jackson National Asset Management
225 West Wacker Drive, Suite 1000