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[logo – American
Funds ®]
The
Tax-Exempt Bond Fund of America
333 South Hope
Street
Los Angeles,
California 90071
Phone (213)
486-9200
Courtney
R. Taylor
Assistant
Secretary
October 29,
2009
Ms. Laura Hatch,
Staff Accountant
U.S. Securities and
Exchange Commission
100 F Street,
NE
Washington, DC
20549
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Re:
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The
Tax-Exempt Bond Fund of America
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File Nos.
002-49291 and 811-02421
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Dear Ms.
Hatch:
This letter is in
response to oral comments we received from you on September 30, 2009 to the
fund’s Post-Effective Amendment No. 40 to the Registration Statement under
the Securities Act of 1933 and Amendment No. 40 to the Registration Statement
under the Investment Company Act of 1940. We appreciate your prompt
response to the filing.
Our responses to
your comments are set forth below. We will incorporate any changes to the fund’s
Registration Statement in a filing pursuant to Rule 485(b) to be automatically
effective on November 1, 2009.
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1.
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General
Comment – prospectus
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Comment: Please
ensure the language in the sections titled “investment objective,” “principal
investment strategies” and “principal risks” is consistent with the
corresponding language in the “investment objectives, strategies and risks”
section of the prospectus. Also please ensure that “fund” is used in
each separate summary rather than referring to “funds.”
Response: We
will modify the language accordingly.
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2.
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Principal
Risks – pages 4 and 10 of the
prospectus
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Comment: Please limit the
“principal risks” section to a description of the risks of investing in the fund
only. For example, please remove the description of a bond’s
effective maturity from the “principal risks section” on page 4 because this
disclosure is not related to a principal risk. Please also remove the
description of municipal bonds from the “principal risks” section on page
11.
Response: We will update the
“principal risks” sections to reflect this comment.
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3.
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Principal
Investment Strategy—page 10 of the
prospectus
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Comment: You have included
risks in the “principal investment strategy” section for American High Municipal
Bond Fund. The prospectus states: “This may make the fund more
susceptible to certain conomic, political or regulatory occurrences. As a
result, the potential for fluctuations in the fund’s share price may
increase.” Please remove this disclosure from the principal
investment strategy as it describes a risk, not a strategy.
Summary: The
“principal investment strategy” section has been modified in response to this
comment. The risk disclosure has been moved to the “principal risks”
section.
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4.
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Pincipal
Investment Strategy – page 10 and throughout
prospectus
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Comment: If the fund may
invest in securities rated below investment grade, please use the term, “junk
bonds.”
Response: We have included
this term in the prospectus as applicable.
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5.
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Principal
Investment Strategy— prospectus
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Comment: If any of the funds
currently invest significantly in securities rated below investment grade,
please clarify this current practice in the disclosure.
Response: We
have modified the language where applicable to explain that the fund invests in
securities rated BB+ or below or Ba1 or below or unrated but determined by the
fund’s investment adviser to be of equivalent quality.
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6.
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Investment
objective – pages 15, 29 of the
prospectus
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Comment: On page 15
the prospectus states: “The fund's investment objective is to provide you with
current income that is exempt from federal income tax, consistent with its stated
maturity and quality standards and preservation of capital.” Please revise this
language where it appears in the prospectus to indicate that the maturity and
quality standards are the same standards described in the
prospectus. Please make similar changes on page 29.
Response: We
will revise the language on page 15 as follows:
The fund's
investment objective is to provide you with current income, consistent with its maturity
and quality standards described in the prospectus, and preservation of
capital. A similar change will be made on page 29.
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7.
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Principal
Investment Strategies—The Tax-Exempt Fund of California on page
24
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Comment: For The Tax-Exempt
Fund of California, are there any limits on the maturities of securities held by
the fund?
Response: Under normal
circumstances, The Tax-Exempt Fund of California invests substantially in
securities with maturities in excess of three years. This is disclosed in the
fund's statement of additional information.
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8.
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Investment
objectives, strategies and risks – page 37 of the
prospectus
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Comment: To the
extent the fund discloses it’s dollar-weighted average maturity in its summary,
please disclose the dollar-weighed average maturity in the “Investment
objectives, strategies and risks section.”
Response: This
section will be amended to reflect this comment.
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9.
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Investment
Results – on pages 40 and 42 of the
prospectus
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Comment: Please clarify the
last two lines on page 40 as well as the discussion on page 42.
Response: This disclosure will
be removed from the text and included in a footnote relating to Class A
distribution rate in the chart showing additional investment results in the
prospectus.
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10.
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Portfolio
turnover – on page 81 of the
prospectus
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Comment: Please ensure that
you are in compliance with the disclosure requirements regarding the portfolio
turnover rate for American Funds Short-Term Tax-Exempt Bond Fund.
Response: During
the periods reflected the fund was a money market fund, and therefore not
required to include disclosure about its portfolio turnover rate. We
will include the fund’s portfolio turnover rate for all future fiscal year ends,
as required.
Thank you for your
consideration of our response to your comments.
If
you have any questions please do not hesitate to contact Katherine Newhall at
(213) 615-0108 or me at (213) 452-2173.
/s/ Courtney R.
Taylor
Courtney R.
Taylor
Assistant
Secretary