Re: |
Hawaiian Tax-Free Trust (File Nos. 2-92583 and 811-4084)
The Cascades Trust (File Nos. 33-4382 and 811-4626)
Post-Effective Amendments to Registration Statements on Form N-1A
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1.
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Comment:
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The Staff asked that each Registrant provide a letter to the Commission that includes certain "Tandy" acknowledgments with the Registrant's response to the Staff's comments
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Response:
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Tandy representation letters executed in connection with the filing of this response are attached hereto as Exhibit A.
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2.
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Comment:
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The Staff requested that each Registrant add the words "front-end" before "sales charge" in footnote number 1 to the Registrant's fee table to clarify that purchases of $1 million or more have no front-end sales charge.
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Response:
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Each Registrant has revised the disclosure to address the Staff's comment.
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3.
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Comment:
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The Staff requested that each Registrant confirm that the disclosure in the principal risks section of the Registrant's prospectus is consistent with the Registrant's principal investment strategies.
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Response:
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Each Registrant confirms that the disclosure in the principal risks section of the Registrant's prospectus is consistent with the Registrant's principal investment strategies.
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4.
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Comment:
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The Staff noted that Hawaiian Tax-Free Trust states in the disclosure regarding risks associated with investments in Hawaii and other municipal obligations that it may be "affected significantly by adverse economic, political or other events affecting Hawaii and other municipal issuers," and Aquila Tax-Free Trust of Oregon states in the disclosure regarding risks associated with investments in Oregon and other municipal obligations that it may be "affected significantly by adverse economic, political or other events affecting Oregon and other municipal issuers." The Staff requested that each Registrant revise the disclosure to clarify that it addresses the municipal obligations in which the Registrant may invest, rather than investments in municipal issuers generally, and to describe in greater detail the adverse economic, political or other events affecting Hawaii or Oregon municipal issuers, as applicable.
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Response:
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Each Registrant has revised the disclosure referenced by the Staff to clarify that it addresses the municipal obligations in which the Registrant may invest, rather than investments in municipal issuers generally. Each Registrant respectfully submits that it provides sufficient detail regarding adverse economic, political or other events affecting Hawaii or Oregon municipal issuers, as applicable, in the disclosure regarding risks associated with investments in obligations of such municipal issuers and that additional disclosure is not required.
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5.
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Comment:
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The Staff requested that each Registrant confirm that principal risks disclosed in the "Additional Information about the Principal Risks of Investing in the Trust" section of the prospectus also are disclosed in the "Principal Risks" section of the prospectus.
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Response:
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Each Registrant confirms that principal risks disclosed in the "Additional Information about the Principal Risks of Investing in the Trust" section of the prospectus also are disclosed in the "Principal Risks" section of the prospectus.
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Re: | The Cascades Trust (File Nos. 33-4382 and 811-4626) |