SPT Funds Investment Trust
c/o Mutual Fund Administration, LLC
2220 E. Route 66, Suite 226
Glendora, California 91740
November 9, 2021
Division of Investment Management
Securities and Exchange Commission
Washington, D.C. 20549
| Re: | SPT Funds Investment Trust (formerly, Bellatore Investment Trust) (the “Registrant”) File Nos. 811-22159 and 333-148445 |
Ladies and Gentlemen:
Pursuant to Rule 477 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), the Registrant, on behalf of the Fixed Income Fund, National Municipal Fund, U.S. Equity Fund, U.S. Large Value Fund, U.S. Small Company Fund, International Equity Fund, International Large Value Fund, International Small Company Fund and Global Real Estate Securities Fund, hereby requests that the Securities and Exchange Commission (the “Commission”) consent to the withdrawal of the Registrant’s registration statement on Form N-1A (together with all amendments and exhibits thereto) originally filed with the Commission on January 3, 2008 (Accession No.0001144204-08-000311), in connection with the proposed registration of the Funds’ common shares of beneficial interest (together with all amendments and exhibits thereto, the “Registration Statement”). The Registrant has determined not to offer shares of the Funds in the Registration Statement. The Registrant confirms that the Registration Statement has not been declared effective and no securities were issued or sold pursuant to the Registration Statement.
Pursuant to Rule 477(b) of the 1933 Act, we understand this request for withdrawal will be deemed granted as of the date of the filing of this letter unless, within 15 calendar days of the filing of this letter, the Commission notifies the Registrant that the application for withdrawal has not been granted.
The Registrant will file a request to deregister under the Investment Company Act of 1940, as amended.
If you have any questions or need further information, I can be reached at 626-914-1041.
Sincerely,
/s/ Rita Dam
Rita Dam
