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U.S. Securities and Exchange Commission

Securities Act of 1933
Rule 902(b)

November 20, 2018

Response of the Office of International Corporate Finance
Division of Corporation Finance

Paul Dudek
Latham & Watkins LLP
555 Eleventh Street, N.W.
Suite 1000
Washington, D.C. 20004-1304


Deutsche Access Investments Limited
Incoming letter dated November 13, 2018

Dear Mr. Dudek:

We are responding to your request dated November 13, 2018. Unless otherwise noted, capitalized terms in this letter have the same meaning as in your request.

Based on the facts presented, the Division will not recommend enforcement action to the Commission if Deutsche Access Investments Limited offers and sells Transferable Custody Receipts (TraCRs) to U.S. broker-dealers who serve as market makers for TraCRs on Chi-X, a regulated stock exchange in Australia, as part of an offering outside of the United States.

This position is based on the representations made to the Division in your request. Any different facts or conditions might require the Division to reach a different conclusion. Further, this response expresses the Division's position on enforcement action only and does not express any legal conclusion on the question presented.


Michael Coco
Chief, Office of International
Corporate Finance
Division of Corporation Finance

Incoming Letter:

The Incoming Letter is in Acrobat format.


Modified: 11/20/18