0000093832-16-000043.txt : 20160718 0000093832-16-000043.hdr.sgml : 20160718 20160615115507 ACCESSION NUMBER: 0000093832-16-000043 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20160615 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

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



June 15, 2016
 
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. 41 to the Registration Statement on Form N-1A for Capital Cash Management Trust and Amendment No. 37 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 each Registrant confirm that, if it resumes operations as a money market fund, the Registrant will not sell its shares until it has filed an amendment to its registration statement to reflect changes to its policies to comply with Rule 2a-7 as then in effect, and addressed any Staff comments to such amendment to its registration statement.

Response: Each Registrant confirms that, if it resumes operations as a money market fund, the Registrant will not sell its shares until it has filed an amendment to its registration statement to reflect changes to its policies to comply with Rule 2a-7 as then in effect, and addressed any Staff comments to such amendment to its registration statement.

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

Sincerely,

/s/ Jeremy Kantrowitz

Jeremy Kantrowitz