The Frontier Fund
c/o Equinox Fund Management, LLC
1660 Lincoln Street, Suite 100
Denver, Colorado 80264
December 23, 2008
VIA EDGAR
Ms. Jennifer Monick
Staff Accountant
United States Securities and Exchange Commission
Mail Stop 4561
Washington D.C. 20549
| Re: | The Frontier Fund (the “Trust”) Form 10-K for the Fiscal Year ended December 31, 2007 Filed March 18, 2008 File No. 0-51274 |
Dear Ms. Monick:
This letter responds to the comment raised in your letter addressed to Brent Bales dated December 11, 2008. Capitalized terms used in this letter without definition herein have the respective meanings ascribed thereto in the Trust’s Form 10-K for the Fiscal Year ended December 31, 2007.
Form 10-K for the fiscal year ended December 31, 2007
Financial Statements
Notes to Financial Statements
4. Investments in Unconsolidated Trading Companies, pages F-23 to F-25
| 1. | We note your response to prior comment 3 and we are unable to agree with your position as we believe that Rule 3-09 of Regulation S-X is applicable at the separate series level to your trust. Please amend your filing to include financial statements for each trading company which is accounted for under the equity method and which has a significance level in excess of 20% of the investor series. |
Response:
The Trust will file a Form 10-K/A for the fiscal year ended December 31, 2007, which will include financial statements for each trading company. The Trust will file such Form 10-K/A on or about January 15, 2009.
| The Frontier Fund | ||
| (Registrant) | ||
| By: | /s/ S. Brent Bales | |
| S. Brent Bales | ||
| Chief Financial Officer | ||
| Equinox Fund Management, LLC, the | ||
| Managing Owner of The Frontier Fund | ||
| cc: | Mr. Richard Bornhoft | |
| Mr. Ron Montano | ||
| Ms. Rebecca Valdez | ||
| Michael F. Griffin, Esq. | ||
| Robert E. Holton, Esq |
