0001193125-11-221663.txt : 20111213 0001193125-11-221663.hdr.sgml : 20111213 20110812181450 ACCESSION NUMBER: 0001193125-11-221663 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20110812 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CurrencyShares Singapore Dollar Trust CENTRAL INDEX KEY: 0001433994 STANDARD INDUSTRIAL CLASSIFICATION: [6221] IRS NUMBER: 000000000 STATE OF INCORPORATION: NY FISCAL YEAR END: 1031 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: C/O RYDEX INVESTMENTS, ATTN: TIM MEYER STREET 2: 9601 BLACKWELL ROAD, SUITE 500 CITY: ROCKVILLE STATE: MD ZIP: 20850 BUSINESS PHONE: 301-296-5129 MAIL ADDRESS: STREET 1: C/O RYDEX INVESTMENTS, ATTN: TIM MEYER STREET 2: 9601 BLACKWELL ROAD, SUITE 500 CITY: ROCKVILLE STATE: MD ZIP: 20850 CORRESP 1 filename1.htm SEC Correspondence
  August 12, 2011                      

ATTORNEYS AT LAW

 

321 NORTH CLARK STREET, SUITE 2800

CHICAGO, IL 60654-5313

312.832.4500 TEL

312.832.4700 FAX

foley.com

   

WRITER’S DIRECT LINE

312.832.5178

pdaugherty@foley.com EMAIL

BY EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

 

  Re: CurrencyShares South African Rand Trust

CurrencyShares Singapore Dollar Trust

CurrencyShares Russian Ruble Trust

Ladies and Gentlemen:

On behalf of Rydex Specialized Products LLC (the “Sponsor”), sponsor of the above-captioned Trusts (collectively, the “Trusts”), we are filing with you, today, Registration Statements on Form S-3 for each of the Trusts (the “Registration Statements”). We are writing to advise you of a disclosure practice adopted by the Sponsor in preparing the Registration Statements, as that information may help you decide whether to review the Registration Statements.

Unrelated to the filings made today, the Sponsor, as sponsor of the CurrencyShares Chinese Renminbi Trust (the “Renminbi Trust”), has prepared and filed a Registration Statement (File No. 333-17640) on Form S-1 (the “Renminbi Registration Statement”) and, in response to a Staff comment letter dated June 28, 2011, a pre-effective Amendment No. 1 to the Renminbi Registration Statement (“Amendment No. 1”). Earlier this week, Erin Martin, Esq., of the Staff, advised us orally that Amendment No. 1 satisfied all of the Staff’s comments made in the Renminbi Comment Letter (other than a Staff reminder that audited financial statements would need to be filed in another pre-effective amendment to the Renminbi Registration Statement).

We hereby advise you that the comments made in the Renminbi Comment Letter have been taken into account and resolved in the Registration Statements as if the Renminbi Comment Letter had addressed the Registration Statements. The Trusts and the offerings to be made pursuant to the Registration Statements are structurally identical to the Renminbi Trust and the offering to be made under the Renminbi Registration Statement as amended. Accordingly, we respectfully submit that the public interest and the protection of investors would not be served by Staff review of any of these Registration Statements.

Should there be any question or concern about any of these filings, please call Patrick Daugherty at (312) 832-5178. In his absence, contact Jacob Babcock at (312) 832-4373.

 

Respectfully submitted,
FOLEY & LARDNER LLP
By:  

/s/ Patrick Daugherty

  Patrick Daugherty

 

cc: Mr. Nickolaos Bonos

Mr. Kevin Farragher

Jacob Babcock, Esq.

 

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