April 28, 2010
Ms. Laura E. Hatch
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
Re: GAMCO Global Series Funds, Inc. (the "Company")
Post-Effective Amendment No. 22 to the Registration Statement
on Form N-1A (33-66262)
Dear. Ms. Hatch:
This letter responds to your comments communicated by telephone on
April 7 and April 22 2010, with respect to the Post-Effective Amendment No. 22
to the Registration Statement on Form N-1A (the "Registration Statement") of the
Company that was filed with the Securities and Exchange Commission (the "SEC")
on February 26, 2010 (accession number 0000950123-10-017797), with respect to
the GAMCO Global Telecommunications Fund, the GAMCO Global Growth Fund, the
GAMCO Global Opportunity Fund and the GAMCO Global Convertible Securities Fund
(each, a "Fund" and together, the "Funds"), the four series of the Company.
In addition, in connection with this filing, the Company hereby states
the following:
1. The Company acknowledges that in connection with the comments
made by the Staff of the SEC, the Staff has not passed on the
accuracy or adequacy of the disclosure made herein, and the
Company and its management are solely responsible for the
content of such disclosure;
2. The Company acknowledges that the Staff's comments, and
changes in disclosure in response to the Staff's comments, do
not foreclose the SEC or other regulatory body from the
opportunity to seek enforcement or take other action with
respect to the disclosure made herein; and
3. The Company represents that neither it nor its management will
assert the Staff's comments or changes in disclosure in
response to the Staff's comments as a defense in any action or
proceeding by the SEC or any person.
The Company's responses to your comments are reflected below.
Comments that applied to both the Class AAA Shares prospectus and the
Class ABCI Shares prospectus have only been addressed once. The
substance of your comments has been restated for your ease of
reference.
COMMENT #1-COVER PAGE: You requested that the Company pare down the
information in the top left hand corner to remove duplicative
references.
RESPONSE #1: The Company has deleted the following
parenthetical language that appears at the end of the
disclosure in the top left hand corner: "(Net Asset Value per
share may be obtained daily by calling 800-GABELLI after 7:00
p.m.)."
COMMENT #2-COVER PAGE: You requested that the Company add the required
legend disclosure if the Company intends to utilize a summary
prospectus.
RESPONSE #2: The Company will not be utilizing a summary
prospectus at this time and therefore the legend has not been
added.
COMMENT #3-PRINCIPAL INVESTMENT STRATEGIES (GAMCO GLOBAL
TELECOMMUNICATIONS FUND): You noted that because of Rule 35d-1 under
the Investment Company Act of 1940 (the "1940 Act") and the Fund's
policy of investing 80% of its net assets in stocks in the
telecommunications industry (the " 80% Policy"), the Telecommunications
Fund should have a concentration policy to the effect that at least 25%
of its assets will be invested in the telecommunications industry (the
"Concentration Policy") and that such policy should be a fundamental
policy. Consequently, you requested that the Telecommunications Fund
add disclosure to the Company's Statement of Additional Information
("SAI") that the Telecommunications Fund has a non-fundamental
Concentration Policy. Additionally, you requested that the Company
represent that at the next meeting of shareholders, a proposal be
presented to the shareholders of the Telecommunications Fund seeking
shareholder approval of the Concentration Policy as a fundamental
policy of the Telecommunications Fund.
RESPONSE #3: The Company will set forth in its SAI a
description of the Telecommunications Fund's non-fundamental
25% concentration policy regarding the telecommunications
industry, but will also note that such policy may not be
changed without shareholder approval in accordance with
Section 13(a)(3) of the 1940 Act. The SAI will also state that
at the next shareholder meeting of the Company, it will
present a proposal to the shareholders of the
Telecommunications Fund seeking shareholder approval of the
Concentration Policy as a fundamental policy of the
Telecommunications Fund, pursuant to an undertaking given by
the Company to the SEC.
COMMENT #4-PRINCIPAL INVESTMENT STRATEGIES: (ALL FUNDS): Because each
Fund has the word "global" in its fund name, you requested that the
Company state that each Fund invests at least 40% of its total net
assets in non-U.S. securities and that each Fund invest in securities
of issuers in at least three countries.
Additionally, you requested that this disclosure be added in either the
"Principal Investment Strategies" section or the Item 9 disclosure.
RESPONSE #4: Based on conversations between the Staff and
Company counsel, the following language has been proposed and
agreed upon with respect to the disclosure in the prospectus
Summary for the Convertible Securities Fund under "Principal
Investment Strategies": "As a global fund, the Convertible
Securities Fund invests in securities of issuers, or related
investments thereof, in at least three countries.
Additionally, over the course of the next six months, the Fund
intends to achieve and maintain thereafter a portfolio in
which at least 40% of its total net assets is invested in
securities of non-U.S. issuers or related investments
thereof."
COMMENT #5-PRINCIPAL INVESTMENT STRATEGIES (GAMCO GLOBAL
TELECOMMUNICATIONS FUND): You noted that the first paragraph states
that the Fund invests primarily in small- and mid-capitalization
issuers. You requested that if the Fund invests a significant portion
of its portfolio in such issuers, the Fund add disclosure to the
"Principal Risks" section.
RESPONSE #5: The GAMCO Global Telecommunications Fund invests
a significant portion of its portfolio in small- and mid-cap
issuers, thus the Fund has added the following risk in the
"Principal Risks" section under "Investing in the Global
Telecommunications Fund involves the following risks:"
o SMALL AND MID-CAPITALIZATION RISK. Risk is greater for the
securities of small- and mid-capitalization companies
(including small unseasoned companies that have been in
operation less than three years) because they generally are
more vulnerable than larger companies to adverse business or
economic developments and they may have more limited
resources. The securities of small- and mid-capitalization
companies also may trade less frequently and in smaller volume
than larger companies. As a result, the value of such
securities may be more volatile than the securities of larger
companies, and the Fund may experience difficulty in
purchasing or selling such securities at the desired time and
price.
The Funds also added the following risk in the "Information
About the Funds' Investment Objectives, Investment Strategies
and Related Risks" section under "Investing in the Funds
involves the following risks:"
o SMALL AND MID-CAPITALIZATION RISK. GLOBAL TELECOMMUNICATIONS
FUND AND GLOBAL GROWTH FUND ONLY -- Risk is greater for the
securities of small- and mid-capitalization companies
(including small unseasoned companies that have been in
operation less than three years) because they generally are
more vulnerable than larger companies to adverse business
or economic developments and they may have more limited
resources. The securities of small- and mid-capitalization
companies also may trade less frequently and in smaller volume
than larger companies. As a result, the value of such
securities may be more volatile than the securities of larger
companies, and the Fund may experience difficulty in
purchasing or selling such securities at the desired time and
price.
COMMENT #6-PERFORMANCE TABLE (GAMCO GLOBAL TELECOMMUNICATIONS FUND):
You requested that the Fund delete the footnote to the performance
table.
RESPONSE #6: The Fund has deleted the footnote.
COMMENT #7-MANAGEMENT (GAMCO GLOBAL TELECOMMUNICATIONS FUND): You
requested that the Fund create a new paragraph for the sub-section
entitled "The Portfolio Managers."
RESPONSE #7: The Fund has made this formatting change.
COMMENT #8-PRINCIPAL INVESTMENT STRATEGIES (GAMCO GLOBAL GROWTH FUND):
You noted that the first paragraph states that the Fund will invest at
least 65% of its total assets in common stocks of companies involved in
the global marketplace and requested that the Fund provide an
explanation of what "involved in the global marketplace" means.
RESPONSE #8: The GAMCO Global Growth Fund has replaced the
first sentence of the "Principal Investment Strategies"
section of GAMCO Global Growth Fund with the following
sentence:
"Under normal market conditions, the Global Growth Fund will
invest at least 65% of its total assets in common stocks of
companies which the Adviser's portfolio management team for
the Global Growth Fund believes are likely to have rapid
growth in revenues and earnings and potential for above
average capital appreciation or are undervalued."
COMMENT #9-PRINCIPAL INVESTMENT STRATEGIES (GAMCO GLOBAL GROWTH FUND):
You noted that the first paragraph states that the Fund invests in
small- and mid-capitalization issuers. You requested that if the Fund
invests a significant portion of its portfolio in such issuers, the
Fund add disclosure to the "Principal Risks" section.
RESPONSE #9: The GAMCO Global Growth Fund has revised the
first sentence of the second paragraph under the "Principal
Investment Strategies" section to read:
"The Global Growth Fund invests primarily in common stocks of
foreign and domestic mid-capitalization and
large-capitalization issuers."
The GAMCO Global Growth Fund has added the following risk
under "Investing in the Global Growth Fund involves the
following risks:":
o MID-CAPITALIZATION RISK. Risk is greater for the securities
of mid-capitalization companies because they generally are
more vulnerable than larger companies to adverse business or
economic developments and they may have more limited
resources. The securities of mid-capitalization companies also
may trade less frequently and in smaller volume than larger
companies. As a result, the value of such securities may be
more volatile than the securities of larger companies, and the
Fund may experience difficulty in purchasing or selling such
securities at the desired time and price.
The Funds also added the following risk in the "Information
About the Funds' Investment Objectives, Investment Strategies
and Related Risks" section under "Investing in the Funds
involves the following risks:"
o MID-CAPITALIZATION RISK. GLOBAL GROWTH FUND ONLY --Risk is
greater for the securities of mid-capitalization companies
because they generally are more vulnerable than larger
companies to adverse business or economic developments and
they may have more limited resources. The securities of
mid-capitalization companies also may trade less frequently
and in smaller volume than larger companies. As a result, the
value of such securities may be more volatile than the
securities of larger companies, and the Fund may experience
difficulty in purchasing or selling such securities at the
desired time and price.
COMMENT #10-PRINCIPAL INVESTMENT STRATEGIES (GAMCO GLOBAL GROWTH FUND):
You noted the second paragraph states that the Fund may invest in
emerging markets and requested that the Fund add disclosure to the
"Principal Risks" section if the Fund invests a significant portion of
its portfolio in emerging markets.
RESPONSE #10: The GAMCO Global Growth Fund does not invest a
significant portion of its portfolio in emerging markets.
COMMENT #11-FEES AND EXPENSES OF THE FUND (GAMCO GLOBAL OPPORTUNITY
FUND): You requested that the last sentence in the footnote to the Fee
Table be moved to the statutory section of the prospectus.
RESPONSE #11: This sentence already exists in the statutory
section of the prospectus in the section entitled "Management
of the Funds." The Fund has deleted the sentence in the
footnote to the Fee Table.
COMMENT #12-PRINCIPAL INVESTMENT STRATEGIES (GAMCO GLOBAL OPPORTUNITY
FUND): You noted that the second paragraph states that the Fund invests
in small-capitalization issuers. You requested that if the Fund invests
a significant portion of its portfolio in such issuers, the Fund add
disclosure to the "Principal Risks" section.
RESPONSE #12: The GAMCO Global Opportunity Fund has added the
following risk under "Investing in the Global Opportunity Fund
involves the following risks:":
o SMALL CAPITALIZATION RISK. Risk is greater for the
securities of small-capitalization companies (including small
unseasoned companies that have been in operation less than
three years) because they generally are more vulnerable than
larger companies to adverse business or economic developments
and they may have more limited resources. The securities of
small-capitalization companies also may trade less frequently
and in smaller volume than larger companies. As a result, the
value of such securities may be more volatile than the
securities of larger companies, and the Fund may experience
difficulty in purchasing or selling such securities at the
desired time and price.
The Funds also added the following risk in the "Information
About the Funds' Investment Objectives, Investment and Related
Risks" section under "Investing in the Funds involves the
following risks:"
o SMALL CAPITALIZATION RISK. GLOBAL OPPORTUNITY FUND ONLY --
Risk is greater for the securities of small-capitalization
companies (including small unseasoned companies that have been
in operation less than three years) because they generally are
more vulnerable than larger companies to adverse business or
economic developments and they may have more limited
resources. The securities of small-capitalization companies
also may trade less frequently and in smaller volume than
larger companies. As a result, the value of such securities
may be more volatile than the securities of larger companies,
and the Fund may experience difficulty in purchasing or
selling such securities at the desired time and price.
COMMENT #13-FEES AND EXPENSES OF THE FUND (GAMCO GLOBAL CONVERTIBLE
SECURITIES FUND): You requested that the last sentence in the footnote
to the Fee Table be moved to the statutory section of the prospectus.
RESPONSE #13: This sentence already exists in the statutory
section of the prospectus in the section entitled "Management
of the Funds." The Fund has deleted the sentence in the
footnote to the Fee Table.
COMMENT #14-PRINCIPAL INVESTMENT STRATEGIES (GAMCO GLOBAL CONVERTIBLE
SECURITIES FUND): You noted that this section states that the Fund may
invest
without limit in securities that are not considered investment grade
and requested that the Fund add disclosure to indicate that these
investments are junk bonds.
RESPONSE #14: The GAMCO Global Convertible Fund has added the
following risk under "Investing in the Global Convertible Fund
involves the following risks:":
o LOWER RATED SECURITIES. The Fund may invest up to 25% of its
assets in lower credit fixed income securities that are below
investment grade, including up to 5% of its assets in
securities of issuers that are in default. These securities
may involve major risk exposures such as increased sensitivity
to interest rate and economic changes, and the market to sell
such securities may be limited. These securities are often
referred to in the financial press as "junk bonds."
The Funds also added the following risk in the "Information
About the Funds' Investment Objectives, Investment Strategies
and Related Risks" section under "Investing in the Funds
involves the following risks:"
o LOWER RATED SECURITIES. GLOBAL CONVERTIBLE SECURITIES FUND
ONLY -- The Fund may invest up to 25% of its assets in fixed
income securities that are below investment grade, including
up to 5% of its assets in securities of issuers that are in
default. These securities may involve major risk exposures
such as increased sensitivity to interest rate and economic
changes, and the market to sell such securities may be
limited. These securities are often referred to in the
financial press as "junk bonds."
COMMENT #15-PERFORMANCE TABLE (ALL FUNDS): You requested that the
Company delete the second sentence of the text after the performance
table regarding "Return After Taxes on Distributions and Sale of Fund
Shares" if it is not applicable for a Fund.
RESPONSE #15: If this disclosure is not applicable for a Fund,
the Company will remove it as appropriate.
COMMENT #16-STATEMENT OF ADDITIONAL INFORMATION: You requested that the
Company include the new corporate governance and board member
disclosure.
RESPONSE #16: The Company will include such disclosure.
Should you have any questions regarding the foregoing, please do not
hesitate to contact Helen A. Robichaud at PNC Global Investment
Servicing, Inc., the Fund's Sub-Administrator, at 617-338-4595.
Very truly yours,
Bruce N. Alpert
Gabelli Funds, LLC
cc: Helen A. Robichaud Arlene Lonergan
PNC Global Investment PNC Global Investment
Servicing, Inc. Servicing, Inc.
Peter D. Goldstein Richard Prins
Gabelli Funds, LLC Skadden, Arps, Slate, Meagher & Flom LLP
Leslie Lowenbraun
Skadden, Arps, Slate, Meagher & Flom LLP