Campbell & Company, Inc.
2850 Quarry Lake Drive
Baltimore, Maryland 21209
(410) 413-2600
January 13, 2012
VIA EDGAR
Ms. Jennifer Gowetski
Senior Counsel
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | The Campbell Fund Trust (the “Trust”) |
| | File No. 0-50264 |
| | Form 10-K for the year ended December 31, 2010 |
Dear Ms. Gowetski:
| I am writing in response to your letter dated December 29, 2011 regarding the Trust’s filing referenced above. |
| |
| The following is an item-by-item response to the Staff’s comments in that letter: |
| |
| 1. | The following is the suggested wording to be included in the December 31, 2011 10K for the Trust in response to comment number 1: The Trust’s counterparty with regard to its forward currency and options on forward currency transactions is The Royal Bank of Scotland PLC (“RBS”). The Trust has entered into an International Swap and Derivatives Association, Inc. agreement with RBS. The credit ratings reported by the three major rating agencies for RBS were considered investment grade as of December 31, 2011. The actual ratings for RBS as of December 31, 2011 were as follows: |
Ms. Jennifer Gowetski
Securities and Exchange Commission
January 13, 2012
Page 2
| | Rating Agency | The Royal Bank of Scotland PLC |
| | Standard & Poor’s Rating Services | A-/ STABLE |
| | Moody’s Investors Service | A3/ NEG |
| | Fitch Ratings | A/ STABLE |
In addition,
| · | The Trust is responsible for the adequacy and accuracy of the disclosure in its filing; |
| · | Commission Staff comments or changes to disclosures in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| · | The Trust may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal security laws of the United States. |
| If you have any questions, please call me at 410-413-2654 or our General Counsel, Tom Lloyd, at 410-413-4552. Thank you in advance for your prompt attention to this matter and for your continuing cooperation. |
Sincerely,
/s/ Gregory T. Donovan
Gregory T. Donovan
Chief Financial Officer
