0000093832-15-000017.txt : 20150721 0000093832-15-000017.hdr.sgml : 20150721 20150612100321 ACCESSION NUMBER: 0000093832-15-000017 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20150612 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CAPITAL CASH MANAGEMENT TRUST CENTRAL INDEX KEY: 0000093832 IRS NUMBER: 132780114 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 120 WEST 45TH STREET STREET 2: STE 3600 CITY: NEW YORK STATE: NY ZIP: 10036 BUSINESS PHONE: 2126976666 MAIL ADDRESS: STREET 1: 120 WEST 45TH STREET STREET 2: SUITE 3600 CITY: NEW YORK STATE: NY ZIP: 10036 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 cmt4015cor.htm

MORGAN, LEWIS & BOCKIUS LLP
ONE FEDERAL STREET
BOSTON, MASSACHUSETTS 02110


June 12, 2015
 
 
 

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

 
Churchill Cash Reserves Trust
 
Registration Statement on Form N-1A - File No. 811-4229

Ladies and Gentlemen:
 
    This letter is to respond to a comment we received from Ms. Ashley Vroman-Lee of the Staff of the Division of Investment Management of the Securities and Exchange Commission regarding Amendment No. 40 to the Registration Statement on Form N-1A for Capital Cash Management Trust and Amendment No. 36 to the Registration Statement on Form N-1A for Churchill Cash Reserves Trust.  Following is the Staff’s comment and the Registrants’ response thereto:
 
1.
Comment:
The Staff requested that, in its next annual update, each Registrant add disclosure confirming that, if it resumes operations as a money market fund, the Registrant will, prior to resuming operations, change its policies to comply with Rule 2a-7 as then in effect and amend its registration statement to reflect such changes.
 
 
Response:
Each Registrant confirms that, in its next annual update, the Registrant will add disclosure confirming that, if it resumes operations as a money market fund, the Registrant will, prior to resuming operations, change its policies to comply with Rule 2a-7 as then in effect and amend its registration statement to reflect such changes.
 
    Please call the undersigned at (617) 951-8458 or Toby Serkin at (617) 951-8760 with any questions.

Sincerely,

/s/ Jeremy Kantrowitz

Jeremy Kantrowitz