SEC-generated letter Frontier Heritage Fund

UPLOAD [Cover] - SEC-generated letter

Published: 2015-01-29 16:02:10
Submitted: 2015-01-29
filename1.pdf


                                                          January 29, 2015

Via E-mail
Mr. Vance Sanders
Chief Financial Officer
Equinox Frontier Funds
c/o Equinox Fund Management, LLC
1775 Sherman Street, Suite 2500
Denver, CO 80203

       Re:    Equinox Frontier Funds
              Form 10-K for year ended December 31, 2013
              Filed on March 31, 2014
              File No. 000-51274

Dear Mr. Vance:

       We have reviewed your response letter dated January 22, 2015 and have the following
comments. In our comments, we may ask you to provide us with information so we may better
understand your disclosure.

       Please respond to this letter within ten business days by amending your filings, by
providing the requested information, or by advising us when you will provide the requested
response. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

       After reviewing any amendments to your filings and the information you provide in
response to these comments, we may have additional comments.

Form 10-K for the year ended December 31, 2013

Financial Statements

Series Financial Statements, page F-2

Statements of Cash Flows, page F-28

1.     We note your response to our prior comment one. We remain unclear as to the nature of
       the line item net change in ownership allocation of total return swaps. Please advise.
       This comment also applies to the Trust financial statements.


Mr. Vance Sanders
Equinox Frontier Funds
January 29, 2015
Page 2

Notes to Financial Statements, page F-32

General

2.     We note your response to our prior comment two. Please tell us if the amount of cash
       held by others exceeds the amount of your restricted cash. To the extent that the cash
       held by others exceeds your restricted cash, please confirm that you will disclose the
       amount of cash held by others within your footnotes in future periodic filings. This
       comment also applies to the Trust financial statements.

3.     We note your response to our prior comment two. Please tell us if any investments,
       including U.S. treasury securities, are held by others. To the extent that any investments
       are held by others, please confirm that you will disclose those amounts in future periodic
       filings. This comment also applies to the Trust financial statements.

4.     We note your response to our prior comment five. We continue to be unclear about the
       nature of the line item “change in ownership allocation of total return swaps” on page F-
       44. Please advise.

       You may contact Jennifer Monick, Senior Staff Accountant, at 202-551-3295 or the
undersigned at 202-551-3438 if you have questions.

                                                            Sincerely,

                                                            /s/ Robert F. Telewicz, Jr.

                                                            Robert F. Telewicz, Jr.
                                                            Senior Staff Accountant



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Document Modified: 2015-01-29 16:02:38
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