February 21, 1995
SECURITIES AND EXCHANGE COMMISSION
450 Fifth Street, N. W.
Judiciary Plaza
Washington, D. C. 20549
RE: Rule 24f-2 Notice for TMK/United Funds, Inc. (Money Market Portfolio,
Bond Portfolio, High Income Portfolio, Growth Portfolio, Income
Portfolio, International Portfolio, Small Cap Portfolio, Balanced
Portfolio, and Limited-Term Bond Portfolio)
File Nos. 33-11466 and 811-5017/CIK#810016
Dear Sir or Madam:
1. This Notice is being filed for the fiscal period ended December 31, 1994;
2. At the beginning of such fiscal period Money Market Portfolio, Bond
Portfolio, High Income Portfolio, Growth Portfolio, Income Portfolio,
International Portfolio, Small Cap Portfolio, Balanced Portfolio, and
Limited-Term Bond Portfolio had no securities registered under the
Securities Act of 1933, other than pursuant to this section;
3. During such fiscal period Money Market Portfolio, Bond Portfolio, High
Income Portfolio, Growth Portfolio, Income Portfolio, International
Portfolio, Small Cap Portfolio, Balanced Portfolio, and Limited-Term Bond
Portfolio registered no securities other than pursuant to this section;
4. Money Market Portfolio sold 183,043,231 shares during such fiscal year (a),
and Bond Portfolio sold 3,002,124 shares during such fiscal year (b), and
High Income Portfolio sold 3,768,168 shares during such fiscal year (c),
and Growth Portfolio sold 11,752,596 shares during such fiscal year (d),
and Income Portfolio sold 11,914,285 shares during such fiscal year (e),
and International Portfolio sold 5,355,035 shares during such fiscal period
(f), and Small Cap Portfolio sold 2,722,519 shares during such fiscal
period (g), and Balanced Portfolio sold 1,795,318 shares during such fiscal
period (h), and Limited-Term Bond Portfolio sold 331,301 shares during such
fiscal period (i); and
5. The 183,043,231 shares of Money Market Portfolio were sold during such
fiscal period in reliance upon registration pursuant to this section.
The 3,002,124 shares of Bond Portfolio were sold during such fiscal period
in reliance upon registration pursuant to this section.
The 3,768,168 shares of High Income Portfolio were sold during such fiscal
period in reliance upon registration pursuant to this section.
The 11,752,596 shares of Growth Portfolio were sold during such fiscal
period in reliance upon registration pursuant to this section.
The 11,914,285 shares of Income Portfolio were sold during such fiscal
period in reliance upon registration pursuant to this section.
The 5,355,035 shares of International Portfolio were sold during such
fiscal period in reliance upon registration pursuant to this section.
The 2,722,519 shares of Small Cap Portfolio were sold during such fiscal
period in reliance upon registration pursuant to this section.
The 1,795,318 shares of Balanced Portfolio were sold during such fiscal
period in reliance upon registration pursuant to this section.
The 331,301 shares of Limited-Term Bond Portfolio were sold during such
fiscal period in reliance upon registration pursuant to this section.
This notice is accompanied by an opinion of counsel for Money Market Portfolio,
Bond Portfolio, High Income Portfolio, Growth Portfolio, International
Portfolio, Small Cap Portfolio, Balanced Portfolio and Limited-Term Bond
Portfolio as prescribed by paragraph (b)(1)(v) of Rule 24f-2. We have wired
$1,365.86 in payment of the filing fee for Money Market Portfolio, $1,153.18 in
payment of the filing fee for High Income Portfolio, $17,327.82 in payment of
the filing fee for Growth Portfolio, $23,027.41 in payment of the filing fee for
Income Portfolio, $9,171.83 in payment of the filing fee for International
Portfolio, $5,044.23 in payment of the filing fee for Small Cap Portfolio,
$3,044.89 in payment of the filing fee for Balanced Portfolio, and $566.50 in
payment of the filing fee for Limited-Term Bond Portfolio as prescribed by
paragraph (c) of said Rule. An additional filing fee as prescribed by paragraph
(c) is not required for Bond Portfolio since during such fiscal period the
issuer's net redemptions exceeded sales.
Very truly yours,
Sharon K. Pappas
Secretary
(a)During such fiscal year ended December 31, 1994, Money Market Portfolio
sold 183,043,231 shares in reliance upon registration pursuant to Rule 24f-
2 at an actual aggregate sale price of $183,043,231 and redeemed
179,082,269 shares at an aggregate repurchase price of $179,082,269. None
of such redeemed shares were previously applied by the issuer pursuant to
Section 24e-2(a) in filings made pursuant to Section 24(e)(1) of the
Investment Company Act of 1940. The filing fee, calculated in the manner
specified in Section 6(b) of the Securities Act of 1933, is based on the
actual sale price of $183,043,231 for which shares were sold during the
issuer's previous fiscal year reduced by the actual redemption price of
$179,082,269 for which shares were redeemed by the issuer during such
previous fiscal year.
(b)During such fiscal year ended December 31, 1994, Bond Portfolio sold
3,002,124 shares in reliance upon registration pursuant to Rule 24f-2 at an
actual aggregate sale price of $15,437,912 and redeemed 3,587,525 shares at
an aggregate repurchase price of $18,214,466. None of such redeemed shares
were previously applied by the issuer pursuant to Section 24e-2(a) in
filings made pursuant to Section 24(e)(1) of the Investment Company Act of
1940. Since the shares redeemed during the issuer's fiscal year exceeded
shares sold a filing fee as prescribed in Section 6(b) of the Securities
Act of 1933 is not required.
(c)During such fiscal year ended December 31, 1994, High Income Portfolio sold
3,768,168 shares in reliance upon registration pursuant to Rule 24f-2 at an
actual aggregate sale price of $16,942,683 and redeemed 3,062,321 shares at
an aggregate repurchase price of $13,598,482. None of such redeemed shares
were previously applied by the issuer pursuant to Section 24e-2(a) in
filings made pursuant to Section 24(e)(1) of the Investment Company Act of
1940. The filing fee, calculated in the manner specified in Section 6(b)
of the Securities Act of 1933, is based on the actual sale price of
$16,942,683 for which shares were sold during the issuer's previous fiscal
year reduced by the actual redemption price of $13,598,482 for which shares
were redeemed by the issuer during such previous fiscal year.
(d)During such fiscal year ended December 31, 1994, Growth Portfolio sold
11,752,596 shares in reliance upon registration pursuant to Rule 24f-2 at
an actual aggregate sale price of $73,683,884 and redeemed 3,733,563 shares
at an aggregate repurchase price of $23,433,567. None of such redeemed
shares were previously applied by the issuer pursuant to Section 24e-2(a)
in filings made pursuant to Section 24(e)(1) of the Investment Company Act
of 1940. The filing fee, calculated in the manner specified in Section
6(b) of the Securities Act of 1933, is based on the actual sale price of
$73,683,884 for which shares were sold during the issuer's previous fiscal
year reduced by the actual redemption price of $23,433,567 for which shares
were redeemed by the issuer during such previous fiscal year.
(e)During such fiscal year ended December 31, 1994, Income Portfolio sold
11,914,285 shares in reliance upon registration pursuant to Rule 24f-2 at
an actual aggregate sale price of $83,060,254 and redeemed 2,344,370 shares
at an aggregate repurchase price of $16,281,238. None of such redeemed
shares were previously applied by the issuer pursuant to Section 24e-2(a)
in filings made pursuant to Section 24(e)(1) of the Investment Company Act
of 1940. The filing fee, calculated in the manner specified in Section
6(b) of the Securities Act of 1933, is based on the actual sale price of
$83,060,254 for which shares were sold during the issuer's previous fiscal
year reduced by the actual redemption price of $16,281,238 for which shares
were redeemed by the issuer during such previous fiscal year.
(f)During such fiscal period ended December 31, 1994, International Portfolio
sold 5,355,035 shares in reliance upon registration pursuant to Rule 24f-2
at an actual aggregate sale price of $27,436,654 and redeemed 164,798
shares at an aggregate repurchase price of $838,532. None of such redeemed
shares were previously applied by the issuer pursuant to Section 24e-2(a)
in filings made pursuant to Section 24(e)(1) of the Investment Company Act
of 1940. The filing fee, calculated in the manner specified in Section
6(b) of the Securities Act of 1933, is based on the actual sale price of
$27,436,654 for which shares were sold during the issuer's previous fiscal
period reduced by the actual redemption price of $838,532 for which shares
were redeemed by the issuer during such previous fiscal period.
(g)During such fiscal period ended December 31, 1994, Small Cap Portfolio sold
2,722,519 shares in reliance upon registration pursuant to Rule 24f-2 at an
actual aggregate sale price of $14,980,266 and redeemed 62,826 shares at an
aggregate repurchase price of $352,112. None of such redeemed shares were
previously applied by the issuer pursuant to Section 24e-2(a) in filings
made pursuant to Section 24(e)(1) of the Investment Company Act of 1940.
The filing fee, calculated in the manner specified in Section 6(b) of the
Securities Act of 1933, is based on the actual sale price of $14,980,266
for which shares were sold during the issuer's previous fiscal period
reduced by the actual redemption price of $352,112 for which shares were
redeemed by the issuer during such previous fiscal period.
(h)During such fiscal period ended December 31, 1994, Balanced Portfolio sold
1,795,318 shares in reliance upon registration pursuant to Rule 24f-2 at an
actual aggregate sale price of $9,104,454 and redeemed 54,726 shares at an
aggregate repurchase price of $274,344. None of such redeemed shares were
previously applied by the issuer pursuant to Section 24e-2(a) in filings
made pursuant to Section 24(e)(1) of the Investment Company Act of 1940.
The filing fee, calculated in the manner specified in Section 6(b) of the
Securities Act of 1933, is based on the actual sale price of $9,104,454 for
which shares were sold during the issuer's previous fiscal period reduced
by the actual redemption price of $274,344 for which shares were redeemed
by the issuer during such previous fiscal period.
(i)During such fiscal period ended December 31, 1994, Limited-Term Bond
Portfolio sold 331,301 shares in reliance upon registration pursuant to
Rule 24f-2 at an actual aggregate sale price of $1,658,566 and redeemed
3,156 shares at an aggregate repurchase price of $15,720. None of such
redeemed shares were previously applied by the issuer pursuant to Section
24e-2(a) in filings made pursuant to Section 24(e)(1) of the Investment
Company Act of 1940. The filing fee, calculated in the manner specified in
Section 6(b) of the Securities Act of 1933, is based on the actual sale
price of $1,658,566 for which shares were sold during the issuer's previous
fiscal period reduced by the actual redemption price of $15,720 for which
shares were redeemed by the issuer during such previous fiscal period.
February 21, 1995
TMK/United Funds, Inc. (Money Market Portfolio, Bond Portfolio, High Income
Portfolio, Growth Portfolio, Income Portfolio, International Portfolio,
Small Cap Portfolio, Balanced Portfolio, and Limited-Term Bond Portfolio)
6300 Lamar Avenue, P.O. Box 29217
Shawnee Mission, Kansas 66201-9217
Dear Sir or Madam:
In connection with the public offering of shares of Capital Stock, par value
$0.01 per share, of TMK/United Funds, Inc. (Money Market Portfolio, Bond
Portfolio, High Income Portfolio, Growth Portfolio, Income Portfolio,
International Portfolio, Small Cap Portfolio, Balanced Portfolio, and Limited-
Term Bond Portfolio), I have examined such corporate records and documents and
have made such further investigations and examinations as I deemed necessary for
the purpose of this opinion.
It is my opinion that the 183,043,231 shares of Capital Stock of Money Market
Portfolio, the 3,002,124 shares of Capital Stock of Bond Portfolio, the
3,768,168 shares of Capital Stock of High Income Portfolio, the 11,752,596
shares of Capital Stock of Growth Portfolio, the 11,914,285 shares of Capital
Stock of Income Portfolio, the 5,355,035 shares of Capital Stock of
International Portfolio, the 2,722,519 shares of Capital Stock of Small Cap
Portfolio, the 1,795,318 shares of Capital Stock of Balanced Portfolio, the
331,301 shares of Capital Stock of Limited-Term Bond Portfolio, registration of
which the Notice makes definite in number, were legally issued, fully paid and
nonassessable.
I hereby consent to the filing of this opinion with the Rule 24f-2 Notice.
Very truly yours,
Sharon K. Pappas
Attorney at Law
