-----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, BlEQpv3CcebVgW91g5m4HAQCMEM8pEBlLQEMplx5EQXE0gryQoRKfOkwtgDn8xh9 bSJDa3H16jgquEUP1pFfqA== 0000950136-06-004878.txt : 20061114 0000950136-06-004878.hdr.sgml : 20061114 20060613210525 ACCESSION NUMBER: 0000950136-06-004878 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060613 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CURRENCYSHARES SWISS FRANC TRUST CENTRAL INDEX KEY: 0001353615 STANDARD INDUSTRIAL CLASSIFICATION: MISCELLANEOUS BUSINESS CREDIT INSTITUTION [6159] IRS NUMBER: 000000000 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: C/O RYDEX INVESTMENTS, ATTN: TIM MEYER STREET 2: 9601 BLACKWELL ROAD, SUITE 500 CITY: ROCKVILLE STATE: MD ZIP: 20850 BUSINESS PHONE: 301-296-5129 MAIL ADDRESS: STREET 1: C/O RYDEX INVESTMENTS, ATTN: TIM MEYER STREET 2: 9601 BLACKWELL ROAD, SUITE 500 CITY: ROCKVILLE STATE: MD ZIP: 20850 CORRESP 1 filename1.htm




                                                 ATTORNEYS AT LAW

                                                 ONE DETROIT CENTER
                                                 500 WOODWARD AVENUE, SUITE 2700
                                                 DETROIT, MI  48226-3489
                               June 13, 2006     313.234.7100 TEL
                                                 313.234.2800 FAX
                                                 www.foley.com

                                                 WRITER'S DIRECT LINE
                                                 313.234.7107
                                                 yvanriper@foley.com EMAIL

                                                 CLIENT/MATTER NUMBER
                                                 058081-0113

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Mail Stop 4569
Washington, DC 20549-4561
Attention:        Christian N. Windsor, Esq.
                  Michael Clampitt, Esq.

         Re:      CurrencyShares British Pound Sterling Trust (333-132361)
                           Amendment No. 3 to Form S-1 Filed March 13, 2006

                  CurrencyShares Australian Dollar Trust (333-132362)
                           Amendment No. 2 to Form S-1 Filed March 13, 2006

                  CurrencyShares Canadian Dollar Trust (333-132262)
                           Amendment No. 2 to Form S-1 Filed March 13, 2006

                  CurrencyShares Mexican Peso Trust (333-132367)
                           Amendment No. 2 to Form S-1 Filed March 13, 2006

                  CurrencyShares Swedish Krona Trust (333-132366)
                           Amendment No. 2 to Form S-1 Filed March 13, 2006

                  CurrencyShares Swiss Franc Trust (333-132364)
                           Amendment No. 2 to Form S-1 Filed March 13, 2006

Gentlemen:

         On behalf of the CurrencyShares Trusts identified above (each, a
"Trust"), each sponsored by Rydex Specialized Products LLC d/b/a Rydex
Investments (the "Sponsor"), earlier today we filed the following documents:

               Amendment No. 3 ("British Pound Amendment No. 3") to the
         Registration Statement on Form S-1 filed by the CurrencyShares British
         Pound Trust on March 13, 2006 (the "British Pound Registration
         Statement") and amended on May 9, 2006 ("British Pound Amendment
         No. 1") and June 9, 2006.



BOSTON               LOS ANGELES         SACRAMENTO             TALLAHASSEE
BRUSSELS             MADISON             SAN DIEGO              TAMPA
CHICAGO              MILWAUKEE           SAN DIEGO/DEL MAR      TOKYO
DETROIT              NEW YORK            SAN FRANCISCO          WASHINGTON, D.C.
JACKSONVILLE         ORLANDO             SILICON VALLEY



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June 13, 2006
Page 2



               Amendment No. 2 to the Registration Statement on Form S-1 filed
         by the CurrencyShares Australian Dollar Trust on March 13, 2006 and
         amended on June 9, 2006;

               Amendment No. 2 to the Registration Statement on Form S-1 filed
         by the CurrencyShares Canadian Dollar Trust on March 13, 2006 and
         amended on June 9, 2006;

               Amendment No. 2 to the Registration Statement on Form S-1 filed
         by the CurrencyShares Mexican Peso Trust on March 13, 2006 and amended
         on June 9, 2006;

               Amendment No. 2 to the Registration Statement on Form S-1 filed
         by the CurrencyShares Swedish Krona Trust on March 13, 2006 and amended
         on June 9, 2006; and

               Amendment No. 2 to the Registration Statement on Form S-1 filed
         by the CurrencyShares Swiss Franc Trust on March 13, 2006 and amended
         on June 9, 2006.

         Pursuant to your request, enclosed with this letter is a blacklined
version of British Pound Amendment No. 3 showing the changes made from British
Pound Amendment No. 1 (as amendment No. 2 was made simply to file exhibits to
the Registration Statement).

         On behalf of the Trusts, set forth below are our responses to the
comment letter of Division of Corporation Finance (the "Staff") dated May 24,
2006. For your convenience, the text of each Staff comment is stated in full in
italicized text, and our responses follow each comment.

General Comments

         1. Make corresponding changes to the other CurrencyShares documents.

Response:

         We have incorporated the changes made to the British Pound Registration
Statement and set forth in the British Pound Amendment No. 1 in Amendment No. 2
to the Registration Statement for each Trust filed earlier today.

         2. Please provide the staff with a copy of the EuroCurrency listing
agreement with the NYSE.

Response:

         Enclosed with this letter is a copy of the listing agreement between
the Euro Currency Trust and the New York Stock Exchange.



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June 13, 2006
Page 2

         3. The staff notes that in the absence of a noon buying rate for the
Federal Reserve Bank of New York, the Trustee, in consultation with the Sponsor
may change the measuring metric. Please confirm that in any instance where the
Trustee and Sponsor are required to use this power to change the reference
metric to determine the daily NAV on an other than temporary (one or two day)
basis, the new metric will be disclosed in a post effective amendment as a
fundamental change to the prospectus.

Response:

         On behalf of the Sponsor, we confirm that in any instance where the
Trustee and Sponsor are required to change the reference metric to determine the
daily net asset value (NAV) for a Trust on an other than temporary (one or two
day) basis, the new metric will be disclosed in a post-effective amendment to
that Trust's Registration Statement as a fundamental change to that Trust's
prospectus.

Report of Independent Registered Public Accounting Firm, page F-2

         4. We await the opinion of your independent registered public
accounting firm.

Response:

         The opinion of PricewaterhouseCoopers LLP, an independent registered
public accounting firm, is included in each amendment to the Registration
Statements that was filed earlier today.

         As we discussed with Mr. Clampitt today, with our responses set forth
above, we believe we have satisfied all outstanding Staff comments. Therefore,
the Sponsor is submitting today an acceleration request on behalf of Trust
requesting that each Registration Statement be declared effective on Thursday,
June 14, 2006 at 11:30 a.m. We expect that the Shares of each Trust will begin
trading on the New York Stock Exchange on Wednesday, June 21, 2006.

         Please contact the undersigned at (313) 234-7107 or Patrick Daugherty
at (313) 234-7103 should you have any questions or comments regarding these
responses.

                                             Very truly yours,

                                             /s/ Yvette M. VanRiper

                                             Yvette M. VanRiper


cc:  Timothy Meyer


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