<PAGE>
Law Offices
Drinker Biddle & Reath LLP
Philadelphia National Bank Building
1345 Chestnut Street
Philadelphia, PA 19107-3496
Telephone: (215) 988-2700
Fax: (215) 988-2757
April 23, 1999
VIA EDGAR TRANSMISSION
- ----------------------
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, NW
Washington, DC 20549
Re: The Kent Funds Form N-1A
Post-Effective Amendment No. 30
File Nos. 33-8398 and 811-4824
-------------------------------
Ladies and Gentlemen:
Please accept for filing Post-Effective Amendment No. 30 (the
"Amendment") to the Registration Statement on Form N-1A of The Kent Funds (the
"Trust") under the Securities Act of 1933, as amended (the "1933 Act"), and the
Investment Company Act of 1940, as amended.
The Amendment is being filed pursuant to Rule 485(b) under the
Securities Act of 1933, as amended, to designate April 30, 1999 as the new
effective date for Post-Effective Amendment No. 28 ("PEA 28") to the
Registrant's Registration Statement on Form N-1A that was filed with the
Securities and Exchange Commission on February 26, 1999. The Amendment
incorporates the entirety of PEA No. 28 by reference.
This Amendment does not contain disclosure that would render it
ineligible to become effective under paragraph (b) of Rule 485.
As requested in the staff's generic comment letter dated February 25,
1994, we note for your information that shares of the Trust are marketed in part
through banks.
<PAGE>
Questions and comments concerning the enclosed materials may be
directed to the undersigned at (215) 988-1146.
Sincerely,
/s/ Diana E. McCarthy
---------------------
Diana E. McCarthy
Encl.
cc: Linda Stirling, Esq.
<PAGE>
As filed with the Securities and Exchange Commission on April 23, 1999
Securities Act File No. 33-8398
Investment Company Act File No. 811-4824
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-1A
REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 [X]
Pre-Effective Amendment No.____ [ ]
Post-Effective Amendment No. 30 and/or [X]
REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940 [X]
Amendment No. 31
(Check appropriate box or boxes)
THE KENT FUNDS
--------------
(Exact Name of Registrant as Specified in Charter)
3435 Stelzer Road, Columbus, Ohio 43219
---------------------------------------
(Address of Principal Executive Offices) (Zip Code)
Registrant's Telephone Number, including Area Code: (614) 470-8000
W. Bruce McConnel, III, Esq.
Drinker Biddle & Reath LLP
1345 Chestnut Street, Philadelphia, PA 19107
---------------------------------------------
(Name and Address of Agent for Service)
It is proposed that this filing will become effective:
[X] immediately upon filing pursuant to paragraph (b)
[ ] on (date) pursuant to paragraph (b)
[ ] 60 days after filing pursuant to paragraph (a)(1)
[ ] on (date) pursuant to paragraph (a)(1)
[ ] 75 days after filing pursuant to paragraph (a)(2)
[ ] on (date) pursuant to paragraph (a)(2) of Rule 485.
If appropriate, check the following box:
[X] This post-effective amendment designates a new effective date for a
previously filed post-effective amendment.
Title of Securities Being Registered....................................... None
The purpose of this Post-Effective Amendment to Registrant's Registration
Statement on Form N-1A is to designate April 30, 1999 as the new effective date
for Post-Effective Amendment No. 28 to the Registrant's Registration Statement
on Form N-1A ("Post-Effective Amendment No. 28") as filed pursuant to Rule
485(a) with the Securities and Exchange Commission on February 26, 1999 and
which has not yet become effective. Pursuant thereto, Post-Effective Amendment
No. 28, including the prospectus and statement of additional information
included therein, is incorporated herein in its entirety.
<PAGE>
SIGNATURES
Pursuant to the requirements of the Securities Act of 1933 and the Investment
Company Act of 1940, the Registrant certifies that it meets all of the
requirement for effectiveness of this registration statement under Rule 485(b)
under the Securities Act and has duly caused this Post-Effective Amendment to
its Registration Statement to be signed on its behalf by the undersigned,
thereto duly authorized, in the City of Columbus, in the State of Ohio, on the
23rd day of April, 1999.
THE KENT FUNDS
By: */ s/ James F. Duca, II
---------------------------
James F. Duca, II
President
Pursuant to the requirements of the Securities Act of 1933, this Post-Effective
Amendment to the Registrant's Registration Statement has been signed below by
the following persons in the capacities and on the dates indicated.
<TABLE>
<CAPTION>
SIGNATURES TITLE DATE
- ---------- ------ -----
<S> <C> <C>
*/ s/ James F. Duca, II President April 23, 1999
- ------------------------------
James F. Duca, II
*/s/ Martin R. Dean Treasurer (Principal Accounting April 23, 1999
- ------------------------------
Martin R. Dean and Financial Officer)
*/ s/ Walter B. Grimm Chairman and Trustee April 23, 1999
- ------------------------------
Walter B. Grimm
*/ s/ Joseph F. Damore Trustee April 23, 1999
- ------------------------------
Joseph F. Damore
*/ s/ James F. Rainey Trustee April 23, 1999
- ------------------------------
James F. Rainey
*/ s/ Ronald F. VanSteeland Trustee April 23, 1999
- ------------------------------
Ronald F. VanSteeland
</TABLE>
*By: /s/ Robert L. Tuch
------------------
<PAGE>
Robert L. Tuch
Attorney-in-Fact
* Robert L. Tuch, by signing his name hereto, does hereby sign this document
on behalf of each of the above-named Trustees and Officers of Registrant
pursuant to powers of attorney duly executed by such persons.
<PAGE>
CERTIFICATE OF SECRETARY
The following resolution was duly adopted by the Board of Trustees of
The Kent Funds on August 20, 1998, and remains in full force and effect as of
the date hereof:
RESOLVED, that the Trustees and officers of the Trust who may be
required to execute any amendments to the Trust's Registration Statement
be, and each of them hereby is, authorized to execute a power of attorney
appointing W. Bruce McConnel, III and Robert L. Tuch, and either of them,
their true and lawful attorneys to execute in their name, place and stead,
in their capacity as Trustee or officer, or both, of the Trust any and all
amendments to the Registration Statement, and all instruments necessary or
incidental in connection therewith, and to file the same with the
Securities and Exchange Commission; and either of said attorneys shall have
the power to act thereunder with or without the other of said attorneys and
shall have full power of substitution and resubstitution; and either of
said attorneys shall have full power and authority to do in the name and on
behalf of said Trustees and officers, or any or all of them, in any and all
capacities, every act whatsoever requisite or necessary to be done in the
premises, as full and to intents and purposes as each of said Trustees or
officers, or any or all of them, might or could do in person, said acts of
said attorneys, or either of them, being thereby ratified and approved.
IN WITNESS WHEREOF, I have hereunto signed my name.
DATED: April 23, 1999 By: /s/ Robert L. Tuch
------------------------
Robert L. Tuch
Secretary
<PAGE>
THE KENT FUNDS
POWER OF ATTORNEY
-----------------
I, James F. Duca, II, hereby appoint W. Bruce McConnel, III and Robert
L. Tuch, and either of them, my true and lawful attorneys and agents, with power
of substitution and resubstitution, to perform any and all acts and things and
to execute any and all instruments which said attorneys and agents, or either of
them, may deem necessary or advisable or which may be required to enable The
Kent Funds, a Massachusetts business trust (the "Fund"), to comply with the
Investment Company Act of 1940, as amended, and the Securities Act of 1933, as
amended ("Acts"), and any rules, regulations or requirements of the Securities
and Exchange Commission in respect thereof, in connection with the filing and
effectiveness of any and all amendments (including post-effective amendments) to
the Fund's Registration Statement pursuant to said Acts, including specifically,
but without limiting the generality of the foregoing, the power and authority to
sign in my name and on my behalf as a trustee and/or officer of the Fund any and
all such amendments filed with the Securities and Exchange Commission under said
Acts, and any other instruments or documents related thereto, and I hereby
ratify and confirm all that said attorneys and agents, or either of them, shall
do or cause to be done by virtue hereof.
/s/ James S. Duca, II
------------------------
James F. Duca, II
Date: March 29, 1999
<PAGE>
THE KENT FUNDS
POWER OF ATTORNEY
-----------------
I, Martin R. Dean, hereby appoint W. Bruce McConnel, III and Robert L.
Tuch, and either of them, my true and lawful attorneys and agents, with power of
substitution and resubstitution, to perform any and all acts and things and to
execute any and all instruments which said attorneys and agents, or either of
them, may deem necessary or advisable or which may be required to enable The
Kent Funds, a Massachusetts business trust (the "Fund"), to comply with the
Investment Company Act of 1940, as amended, and the Securities Act of 1933, as
amended ("Acts"), and any rules, regulations or requirements of the Securities
and Exchange Commission in respect thereof, in connection with the filing and
effectiveness of any and all amendments (including post-effective amendments) to
the Fund's Registration Statement pursuant to said Acts, including specifically,
but without limiting the generality of the foregoing, the power and authority to
sign in my name and on my behalf as a trustee and/or officer of the Fund any and
all such amendments filed with the Securities and Exchange Commission under said
Acts, and any other instruments or documents related thereto, and I hereby
ratify and confirm all that said attorneys and agents, or either of them, shall
do or cause to be done by virtue hereof.
/s/ Martin R. Dean
-----------------------
Martin R. Dean
Date: March 29, 1999
<PAGE>
THE KENT FUNDS
POWER OF ATTORNEY
-----------------
I, Walter B. Grimm, hereby appoint W. Bruce McConnel, III and Robert
L. Tuch, and either of them, my true and lawful attorneys and agents, with power
of substitution and resubstitution, to perform any and all acts and things and
to execute any and all instruments which said attorneys and agents, or either of
them, may deem necessary or advisable or which may be required to enable The
Kent Funds, a Massachusetts business trust (the "Fund"), to comply with the
Investment Company Act of 1940, as amended, and the Securities Act of 1933, as
amended ("Acts"), and any rules, regulations or requirements of the Securities
and Exchange Commission in respect thereof, in connection with the filing and
effectiveness of any and all amendments (including post-effective amendments) to
the Fund's Registration Statement pursuant to said Acts, including specifically,
but without limiting the generality of the foregoing, the power and authority to
sign in my name and on my behalf as a trustee and/or officer of the Fund any and
all such amendments filed with the Securities and Exchange Commission under said
Acts, and any other instruments or documents related thereto, and I hereby
ratify and confirm all that said attorneys and agents, or either of them, shall
do or cause to be done by virtue hereof.
/s/ Walter B. Grimm
------------------------
Walter B. Grimm
Date: March 29, 1999
<PAGE>
THE KENT FUNDS
POWER OF ATTORNEY
-----------------
I, Joseph F. Damore, hereby appoint W. Bruce McConnel, III and Robert
L. Tuch, and either of them, my true and lawful attorneys and agents, with power
of substitution and resubstitution, to perform any and all acts and things and
to execute any and all instruments which said attorneys and agents, or either of
them, may deem necessary or advisable or which may be required to enable The
Kent Funds, a Massachusetts business trust (the "Fund"), to comply with the
Investment Company Act of 1940, as amended, and the Securities Act of 1933, as
amended ("Acts"), and any rules, regulations or requirements of the Securities
and Exchange Commission in respect thereof, in connection with the filing and
effectiveness of any and all amendments (including post-effective amendments) to
the Fund's Registration Statement pursuant to said Acts, including specifically,
but without limiting the generality of the foregoing, the power and authority to
sign in my name and on my behalf as a trustee and/or officer of the Fund any and
all such amendments filed with the Securities and Exchange Commission under said
Acts, and any other instruments or documents related thereto, and I hereby
ratify and confirm all that said attorneys and agents, or either of them, shall
do or cause to be done by virtue hereof.
/s/ Joseph F. Damore
-------------------------
Joseph F. Damore
Date: March 29, 1999
<PAGE>
THE KENT FUNDS
POWER OF ATTORNEY
-----------------
I, James F. Rainey, hereby appoint W. Bruce McConnel, III and Robert
L. Tuch, and either of them, my true and lawful attorneys and agents, with power
of substitution and resubstitution, to perform any and all acts and things and
to execute any and all instruments which said attorneys and agents, or either of
them, may deem necessary or advisable or which may be required to enable The
Kent Funds, a Massachusetts business trust (the "Fund"), to comply with the
Investment Company Act of 1940, as amended, and the Securities Act of 1933, as
amended ("Acts"), and any rules, regulations or requirements of the Securities
and Exchange Commission in respect thereof, in connection with the filing and
effectiveness of any and all amendments (including post-effective amendments) to
the Fund's Registration Statement pursuant to said Acts, including specifically,
but without limiting the generality of the foregoing, the power and authority to
sign in my name and on my behalf as a trustee and/or officer of the Fund any and
all such amendments filed with the Securities and Exchange Commission under said
Acts, and any other instruments or documents related thereto, and I hereby
ratify and confirm all that said attorneys and agents, or either of them, shall
do or cause to be done by virtue hereof.
/s/ James F. Rainey
-----------------------
James F. Rainey
Date: March 29, 1999
<PAGE>
THE KENT FUNDS
POWER OF ATTORNEY
-----------------
I, Ronald F. VanSteeland, hereby appoint W. Bruce McConnel, III and
Robert L. Tuch, and either of them, my true and lawful attorneys and agents,
with power of substitution and resubstitution, to perform any and all acts and
things and to execute any and all instruments which said attorneys and agents,
or either of them, may deem necessary or advisable or which may be required to
enable The Kent Funds, a Massachusetts business trust (the "Fund"), to comply
with the Investment Company Act of 1940, as amended, and the Securities Act of
1933, as amended ("Acts"), and any rules, regulations or requirements of the
Securities and Exchange Commission in respect thereof, in connection with the
filing and effectiveness of any and all amendments (including post-effective
amendments) to the Fund's Registration Statement pursuant to said Acts,
including specifically, but without limiting the generality of the foregoing,
the power and authority to sign in my name and on my behalf as a trustee and/or
officer of the Fund any and all such amendments filed with the Securities and
Exchange Commission under said Acts, and any other instruments or documents
related thereto, and I hereby ratify and confirm all that said attorneys and
agents, or either of them, shall do or cause to be done by virtue hereof.
/s/ Ronald F. VanSteeland
----------------------------
Ronald F. VanSteeland
Date: March 29, 1999
