Old Mutual Global Shares Trust
10 High Street, Suite 302
Boston, MA 02110
November 18, 2009
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Attn: John Grzeskiewicz
Re:
Old Mutual Global Shares Trust (the “Trust”)
File Nos. 333-159629 and 811-22304
Dear Mr. Grzeskiewicz:
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Securities Act”), the Trust hereby requests that the effectiveness for Pre-Effective Amendment Number 4 to the Trust’s Registration Statement on Form N-1A be accelerated to 12:00 p.m., New York time, on November 19, 2009, or as soon thereafter as practicable. The Trust hereby confirms that it is aware of its obligations under the Securities Act and the Securities Exchange Act of 1934, as amended.
Very truly yours,
By:
/s/ Eric G. Woodbury
Name:
Eric G. Woodbury
Title:
Secretary
Foreside Fund Services, LLC
Three Canal Plaza, Suite 100
Portland, ME 04101
November 18, 2009
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Attn: John Grzeskiewicz
Re:
Old Mutual Global Shares Trust (the “Trust”)
File Nos. 333-159629 and 811-22304
Dear Mr. Grzeskiewicz:
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Securities Act”), Foreside Fund Services, LLC (“Foreside”), in its capacity as distributor of the shares of the Trust, hereby joins in the request of the Trust that the effectiveness for the Trust’s Pre-Effective Amendment Number 4 to the Trust’s Registration Statement on Form N-1A be accelerated to 12:00 p.m., New York time, on November 19, 2009, or as soon thereafter as practicable. Foreside hereby confirms that it is aware of its obligations under the Securities Act and the Securities Exchange Act of 1934, as amended.
Very truly yours,
By:
/s/ Nanette K. Chern
Name:
Nanette K. Chern
Title:
Vice President