0000093832-12-000010.txt : 20120710 0000093832-12-000010.hdr.sgml : 20120710 20120618093335 ACCESSION NUMBER: 0000093832-12-000010 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20120618 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CAPITAL CASH MANAGEMENT TRUST CENTRAL INDEX KEY: 0000093832 IRS NUMBER: 132780114 STATE OF INCORPORATION: MA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 380 MADISON AVE STREET 2: STE 2300 CITY: NEW YORK STATE: NY ZIP: 10017 BUSINESS PHONE: 2126976666 MAIL ADDRESS: STREET 1: 380 MADISON AVENUE STREET 2: SUITE 2300 CITY: NEW YORK STATE: NY ZIP: 10017 FORMER COMPANY: FORMER CONFORMED NAME: CENTENNIAL CAPITAL CASH MANAGEMENT TRUST DATE OF NAME CHANGE: 19820921 FORMER COMPANY: FORMER CONFORMED NAME: STCM CORP DATE OF NAME CHANGE: 19770201 CORRESP 1 filename1.htm cmt4012cor.htm
 

BINGHAM McCUTCHEN LLP
ONE FEDERAL STREET
BOSTON, MASSACHUSETTS 02110



 
June 18, 2012
 
 
 

VIA EDGAR
 
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549


Re:
Capital Cash Management Trust
 
Registration Statement on Form N-1A
 
(File No. 811-2481)

Ladies and Gentlemen:

This letter is to respond to a comment we received from Mr. Edward Bartz of the Staff of the Division of Investment Management of the Securities and Exchange Commission (the “Commission”) regarding Amendment No. 37 to the Registration Statement on Form N-1A for Capital Cash Management Trust (the “Registrant”).  Following is the Staff’s comment and the Registrant’s response thereto:

Comment:
The Staff noted that the Registrant states in the Registration Statement that it has not offered its shares to the public since December 2, 2003.  The Staff asked the Registrant to confirm that all of its outstanding shares are held by the Registrant’s sponsor or an affiliate of the Registrant’s sponsor.

Response:
The Registrant confirms that all of its outstanding shares are held by Aquila Investment Management LLC, the Registrant’s administrator and a wholly-owned subsidiary of the Registrant’s sponsor, Aquila Management Corporation.

Please call the undersigned at (617) 951-8458 or Toby Serkin at (617) 951-8760 with any questions.


Sincerely,

/s/ Jeremy B. Kantrowitz

Jeremy B. Kantrowitz