Subject: File No. 4-512
From: Ken Simons
Affiliation: Senior Vice President, Sungard Relius

March 31, 2006

Further to the Comment Letter that SunGard Relius submitted on March 20, 2006, we would like to clarify the position from which this statement was written. The comments contained in this letter refer only to the ability of the SunGard Relius recordkeeping system to support 22c-2 compliance on behalf of its clients and their underlying intermediaries. SunGard as a whole is actively working on enhancements to a number of its trust, recordkeeping and investor accounting systems, in addition to developing an ASP service combining data warehousing, analytics and administrative tools, all of which will help enable both intermediaries and fund companies to comply with Rule 22c-2. The development timelines of these and other efforts underway within SunGard are not contingent upon Relius ability to provide its clients with a file extract nor the ability of the Relius clients to test and implement the Rule 22c-2 release in a timely manner.

Michele Coletti, QKA, CEBS
Sr. Business Analyst, Sungard Relius

Ken Simons
Senior Vice President, Sungard Relius