Fund Evaluator:
Comstock Capital Value AAA (COMVX)
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Best Performing in Trading--Inverse Equity Over the Last Year
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Fund Details
Comstock Capital Value AAA Overview
Comstock Capital Value AAA (COMVX) is an actively managed Miscellaneous Trading--Inverse Equity fund. Gabelli launched the fund in 2008.
The investment seeks to maximize total return, consisting of capital appreciation and current income. The fund follows a value oriented strategy and seeks to achieve its investment objective by investing in equity and debt securities, money market instruments, and derivatives. It may invest in, and may shift frequently among, a wide range of asset classes and market sectors. The fund may invest up to 65% of its assets in equity and debt securities of foreign issuers, including those in emerging markets. It may invest without limit in high yield debt securities, but currently the advisor intends to limit such investments to 35% of its assets.
About Comstock Capital Value AAA (COMVX)
There are 4 members of the management team with an average tenure of 4.68 years: Ralph Rocco (2021), Willis Brucker (2021), Joseph Gabelli (2021), Paolo Vicinelli (2021). Management tenure is more important for actively managed funds than passive index funds.
The fund has 1 primary benchmark: S&P 500 (TR) (1970) index with a weighting of 100%. Comstock Capital Value AAA has 142 securities in its portfolio. The top 10 holdings constitute 47.2% of the fund’s assets. The fund meets the SEC requirement of being classified as a diversified fund. The fund is not considered to have an ESG focus with its investment selection and management.
Comstock Capital Value AAA is part of the Other global asset class and is within the Miscellaneous fund group. Comstock Capital Value AAA has 1.8% of its portfolio invested in foreign issues. The overall assets allocated to domestic stock is 72.4%. There is 1.8% allocated to foreign stock, and 2.5% is allocated to preferred stocks. The bond allocation as a percentage of total assets is 0.0% (0.0% domestic bond, 0.0% foreign bond and 0.0% convertible bond). Comstock Capital Value AAA has 22.8% of the portfolio in cash.
Assets Under Management
The fund has $962 million in total assets, which is below the $5 million average for the Trading--Inverse Equity category. Normally, lower assets under management translates to higher average expense ratios, and greater total assets are desired. However, for some investment categories, such as small-cap investing, it may be difficult for the manager to fully employ the desired active strategy if assets grow too large or too quickly.
COMVX Performance and Fees
The expense ratio measures how much of a fund’s assets are used for administrative expenses and operating expenses, including adviser fees and fees for the transfer agent and custodial services. The Comstock Capital Value AAA expense ratio is low compared to funds in the Trading--Inverse Equity category. Comstock Capital Value AAA has an expense ratio of 0.00%, which is 100% lower than its category average, making the fund expense ratio grade a A. While it is difficult to predict returns, it is known that high annual expense ratios reduce your rate of return, and excessive fees are difficult to overcome. Active management normally comes with higher expense ratios than passive index management. Certain investment categories such as small company and foreign also normally have higher expense ratios. It is best to compare fund expense ratios against the category averages for meaningful assessments.
High portfolio turnover can translate to higher expenses and lower aftertax returns. Comstock Capital Value AAA has a portfolio turnover rate of 253%, indicating that holds its assets around 0.0 years. By way of comparison, the average portfolio turnover is 432% for the Trading--Inverse Equity category.
Recently, in the month of July 2026, Comstock Capital Value AAA returned -0.2%, which earned it a grade of D, as the Trading--Inverse Equity category had an average return of 2.2%. The letter grades of A, B, C, D and F are based upon relative rankings within the investment category. A grade of A, for example, would indicate that the return is in the highest 20% for that time period compared to all funds in that category.
Comstock Capital Value AAA has a trailing yield of 1.90%, which is below the 6.77% category average. The fund normally distributes its income annually.
It’s natural to seek the best-performing investments, but you must consider the relationship between risk and return and the impact of costs and taxes on your realized returns.
Comstock Capital Value AAA Grades
Year to date, the fund has returned 3.2%, 17.4 percentage points better than the category, which translates into a grade of A. The fund has returned 6.6% over the past year (grade of A), 7.6% over the past three years (grade of A) and 5.7% per year over the past five years (grade of A) and -3.5% per year over the past 10 years (grade of A).
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COMVX Trailing NAV Total Returns Data as of 7/31/26
| Last Month |
Last Quarter |
Ann'l. 1Yr |
Ann'l. 3Yr |
Ann'l. 5Yr |
Ann'l. 10Yr |
|
| COMVX Return (NAV) | -0.2% | 0.4% | 6.6% | 7.6% | 5.7% | -3.5% |
| COMVX Grade | D | A | A | A | A | A |
| +/- Category | -2.4% | 4.6% | 30.2% | 25.5% | 20.5% | 17.3% |
| Trading--Inverse Equity Avg | 2.2% | -4.1% | -23.6% | -17.9% | -14.8% | -20.8% |
| COMVX Tax Cost Ratio | na | na | 0.8% | 0.8% | 0.5% | 0.2% |
COMVX Annual NAV Total ReturnsData as of 7/31/26
| 2026 | 2025 | 2024 | 2023 | 2022 | 2021 | 2020 | 2019 | 2018 | 2017 | 2016 | |
| COMVX Return (NAV) | 3.2% | 11.2% | 4.4% | 6.5% | 4.1% | -2.2% | -5.1% | -25.9% | 7.5% | -20.5% | -20.5% |
| COMVX Grade | A | A | A | A | F | A | A | B | C | B | C |
| +/- Category | 17.4% | 32.8% | 18.3% | 30.3% | -12.2% | 18.9% | 35.9% | 6.0% | 0.2% | 8.3% | 1.7% |
| Trading--Inverse Equity Avg | -14.2% | -21.5% | -13.9% | -23.7% | 16.4% | -21.1% | -41.0% | -31.9% | 7.3% | -28.9% | -22.3% |
| Risk Measures | |
| Standard Deviation: | 3.5% |
| Total Risk Index: | 0.29 - Low |
| Category Risk Index: | 0.15 - Low |
| Category Risk Grade: | A (1% Rank) |
| Beta: | 0.14 |
| R-Squared: | 29% |
| Leveraged Fund: | No |
| Inverse Fund: | No |
| Portfolio Characteristics | |
| Equity Investment Style: | Small-Cap Blend |
| Bond Investment Style: | na |
| Yield: | 1.9% |
| Dividend Distribution: | Annually |
| Cap Gains Distribution: | |
| Total Assets: | $11 Mil |
| Fund Total Assets: | $ 1 Mil |
| Share Class Type: | Other |
| Portfolio Turnover: | 253% |
Management Team
| Number of Managers: 4 | |||
| Longest Tenure: 4.7 years | |||
| Average Tenure: 4.7 years | |||
| Managers (Year): Rocco Ralph (2021), Brucker Willis (2021), Gabelli Joseph (2021), Vicinelli Paolo (2021) | |||
Portfolio Composition (as of 4/30/26)
| # of Holdings: | 142 |
| % in Top 10 Holdings: | 47.2% |
| Fund is Non-Diversified: | No |
| % in Foreign Issues: | 1.8% |
Portfolio Allocation |
|
| Domestic Stock: | 72.4% |
| Foreign Stock: | 1.8% |
| Preferred Stock: | 2.5% |
| Domestic Bond: | 0.0% |
| Foreign Bond: | 0.0% |
| Convertible Bond: | 0.0% |
| Other: | 0.5% |
| Cash: | 22.8% |
Purchase Information
| Fund Family: | Gabelli |
| Phone Number: | 800-422-3554 |
| Website: | www.gabelli.com |
| Status: | Closed |
| Inception Date: | December 8, 2008 |
| Min. Initial Purchase: | $1,000 |
| Min. Initial IRA Purchase: | $ 250 |
| True No-Load: | Yes |
| Front Load Maximum: | 0.00% |
| Deferred Charge Maximum: | 0.00% |
| Redemption Charge Maximum: | 2.00% |
| 12b-1 Fee: | 0.25% |
Expenses and Fees | |
| Expense Ratio (%): | 0.00% ( Rating : Low ) |
| Category Average Expense Ratio (%): | 1.97% |
| Share Class: | Comstock Capital Value A |
| Min. Subsequent Purchase: | $ 0 |
| Min. Subsequent IRA Purchase: | $ 0 |
