-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, LzbmJtCaPM8oiEalv8qjvev4FiNhP/+yl2LG2SNJRE6zQhKp6tQ1NzN9KLblAS8W jIl+7vwYxAsRiqGKxJeZ+A== 0000899140-08-000091.txt : 20080303 0000899140-08-000091.hdr.sgml : 20080303 20080107165343 ACCESSION NUMBER: 0000899140-08-000091 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20080107 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SMITH BARNEY WESTPORT FUTURES FUND LP CENTRAL INDEX KEY: 0001037189 STANDARD INDUSTRIAL CLASSIFICATION: [6221] IRS NUMBER: 000000000 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: C/O SMITH BARNEY FUTURES MANAGEMENT INC STREET 2: 390 GREENWICH ST CITY: NEW YORK STATE: NY ZIP: 10013 BUSINESS PHONE: 2127235424 MAIL ADDRESS: STREET 1: C/O SMITH BARNEY FUTURES MANAGEMENT INC STREET 2: 390 GREENWICH ST CITY: NEW YORK STATE: NY ZIP: 10013 CORRESP 1 filename1.txt Willkie Farr & Gallagher LLP 787 Seventh Avenue New York, New York 10019 January 7, 2008 Mail Stop 4561 - -------------- VIA EDGAR AND FEDEX - ------------------- Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington D.C. 20549 Attn: Kevin Woody Branch Chief Re: Salomon Smith Barney Westport Futures Fund L.P. (the "Partnership") Form 10-K for the fiscal year ended December 31, 2006 Form 10-Q for the quarterly period ended June 30, 2007 File No. 000-24111 ------------------------------------------------------------------- Ladies and Gentlemen: On behalf of this firm's client, Citigroup Managed Futures LLC, the general partner of the Partnership (the "General Partner"), we respectfully submit below the General Partner's responses to the comments of the staff (the "Staff") of the Securities and Exchange Commission (the "Commission") in a letter dated September 26, 2007 to Jennifer Magro, Chief Financial Officer of the General Partner. For your convenience, the Staff's comments are indicated in italics, followed by the General Partner's response. Form 10-K for the fiscal year ended December 31, 2006 - ----------------------------------------------------- Notes to the Financial Statements - --------------------------------- 7. Financial Instrument Risks - ------------------------------ 1. We note that the Partnership may make investments in assets that are not traded on an exchange. Explain to us the Partnership's policy for determining the fair value of these assets. Additionally, to the extent the Partnership has any such investments as of period end; tell us how you determined that it would not be necessary to disclose the Partnership's methodology for calculating the fair value in the policy footnote. Kevin Woody January 7, 2008 Page 2 The majority of the Partnership's trading is in exchange traded futures contracts for which daily settlement prices are available. Currently, all off-exchange contracts traded by the Partnership are traded in commodity interests for which there is generally a liquid underlying market and are valued by reference to the settlement price of a similar exchange-traded product. The Partnership's off-exchange contracts to date, therefore, have been valued based on the settlement price of a similar exchange-traded product. In the event the Partnership trades an off-exchange contract for which no similar exchange traded product exists, the General Partner will value the off-exchange contract using one or more alternative valuation methods which may include, but is not necessarily limited to, reliance on assessments made by internal product control teams affiliated with the General Partner. The General Partner will include a description of any such alternative valuation methods in the Partnership's policy footnote in such event. The Partnership's current disclosure states that: "The majority of the Partnership's positions will be exchange-traded futures contracts, which will be valued daily at settlement prices published by the exchanges. If applicable, the Partnership's spot and forward foreign currency contracts will also be valued at published daily settlement prices or at dealers' quotes. The General Partner expects that under normal circumstances substantially all of the Partnership's assets will be valued by objective measures and without difficulty." The General Partner believes that this disclosure is currently accurate. * * * * Should you have any questions, please do not hesitate to contact the undersigned at (212) 728-8727. Very truly yours, /s/ Rita M. Molesworth Rita M. Molesworth cc: Jennifer Magro Gabriel Acri Jennifer Monick, Securities and Exchange Commission -----END PRIVACY-ENHANCED MESSAGE-----