1.
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Comment:
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The Staff noted that the Registrants are using an old version of Form N-CSR for shareholder report filings and requested that the Registrants use the
current form of Form N-CSR for future filings.
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Response:
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The Registrants confirm that they will use the current form of Form N-CSR for future shareholder report filings.
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2.
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Comment:
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The Staff noted that the Statement of Operations for each Fund notes an expense line item for Chief Compliance Officer (“CCO”) services. The Staff
requested that the Registrants explain why the Funds are paying such expense, noting that the CCO is an employee of the Funds’ Manager and that each Fund’s investment advisory agreement provides that the Manager shall pay all compensation of
officers, and employees of the Fund who are affiliated persons of the Manager. However, the Staff acknowledged that Note 3 to each Fund’s financial statements states that, under a compliance agreement with the Manager, the Manager is
compensated by the Fund for Chief Compliance Officer related services provided to enable the Fund to comply with Rule 38a-1 of the Investment Company Act of 1940, as amended (the “1940 Act”).
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Response:
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The Registrants note that, as disclosed in Note 3 to each Fund’s financial statements and as acknowledged by the Staff, each Fund has entered into a
separate compliance agreement with the Manager. Each compliance agreement addresses the provision of compliance services to the Fund in accordance with Rule 38a-1 under the 1940 Act, and provides that the Fund shall pay the Manager a fee for
the compliance services provided under the agreement. Such fee is disclosed in the line item to the Statement of Operations referenced by the Staff. Going forward, the Registrants will change the line item and the Note to the financial
statements to refer to payment for compliance services rather than Chief Compliance Officer services. Compliance services are not provided to the Funds by the Manager under the Funds’ investment advisory agreements with the Manager. Each
Registrant confirms that it will file the applicable compliance agreement as an exhibit to its next annual update of its registration statement on Form N-1A.
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CIK
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File No
|
Fund Name
|
Registrant Name
|
Date of Financial Statements Reviewed
|
S000009167
|
811-03578
|
Aquila Three Peaks High Income Fund
|
AQUILA FUNDS TRUST
|
12/31/2019
|
S000041644
|
811-03578
|
Aquila Three Peaks Opportunity Growth Fund
|
AQUILA FUNDS TRUST
|
12/31/2019
|
S000041641
|
811-04503
|
Aquila Churchill Tax-Free Fund of Kentucky
|
AQUILA MUNICIPAL TRUST
|
3/31/2020
|
S000041642
|
811-04503
|
Aquila Narragansett Tax-Free Income Fund
|
AQUILA MUNICIPAL TRUST
|
3/31/2020
|
S000041643
|
811-04503
|
Aquila Tax-Free Fund For Utah
|
AQUILA MUNICIPAL TRUST
|
3/31/2020
|
S000041640
|
811-04503
|
Aquila Tax-Free Fund of Colorado
|
AQUILA MUNICIPAL TRUST
|
3/31/2020
|
S000009132
|
811-04503
|
Aquila Tax-Free Trust of Arizona
|
AQUILA MUNICIPAL TRUST
|
3/31/2020
|
S000009154
|
811-02481
|
Capital Cash Management Trust
|
CAPITAL CASH MANAGEMENT TRUST
|
12/31/2019
|
S000006648
|
811-04626
|
Aquila Tax-Free Trust of Oregon
|
CASCADES TRUST
|
3/31/2020
|
S000009108
|
811-04084
|
Hawaiian Tax-Free Trust
|
HAWAIIAN TAX FREE TRUST
|
3/31/2020
|