COMMENTS RECEIVED ON NOVEMBER 12, 2016
FROM EDWARD BARTZ
FIDELITY OXFORD STREET TRUST II (File No. 811-22893)
Fidelity Commodity Strategy Central Fund
AMENDMENT NO. 8
“Fund Summary” (Part A of the Registration Statement)
“Portfolio Manager(s)”
C:
The Staff requests confirmation that all of the portfolio managers are jointly and primarily responsible for the day to day operations of the fund.
R:
We believe this disclosure appropriately identifies each portfolio manager as required by Form N−1A,
Item 5(a), Instruction 2.
“Investment Policies and Limitations” (Part B of the Registration Statement)
“Concentration”
C:
The Staff requests that we disclose later in the registration statement that if a fund is a protection seller under a credit default swap, it will segregate assets equal to the full notional amount of the swap agreement.
R:
We confirm that, if a fund holds any credit default swaps in its portfolio, it would expect at this time to segregate assets equal to the full notional amount of each transaction. We are aware that the SEC has been analyzing the segregation requirements for mutual funds using derivatives and that rulemaking on the subject may be forthcoming. In the absence of staff guidance or rulemaking on the subject, we do not believe it is prudent to include our internal segregation policies in our disclosure. Accordingly, we respectfully decline to modify the disclosure as suggested.
