Deutsche Investment Management Americas Inc.
One Beacon Street
Boston, MA 02108
July 27, 2017
Via EDGAR
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Ms. Marianne Dobelbower
RE: | Post-Effective Amendment No. 56 (the “Amendment”) to the Registration Statement on Form N-1A of Deutsche Tax-Exempt Portfolio (formerly known as Tax-Exempt Portfolio) (the “Fund”), a series of Cash Account Trust (the “Registrant”) (Reg. Nos. 033-32476, 811-05970) |
Dear Ms. Dobelbower:
This letter is being submitted in response to the comments of the Staff of the Securities and Exchange Commission (“SEC”) received on July 25, 2017 in regards to the above-captioned Post-Effective Amendment for the Registrant filed with the SEC on May 31, 2017.
The Staff’s comments are summarized below, followed by the Registrant’s responses:
1. | Comment: Please consider revising the fund’s 80% investment policy to indicate that net assets includes borrowings for investment purposes. |
Response: In response to the Staff's comment, we have modified the Fund's disclosure to clarify that net assets for purposes of the Fund’s 80% investment policy includes any borrowings for investment purposes. Please note that we have made this clarifying change in reliance on Rule 35d-1 and the SEC Staff guidance provided in its response to Question 1 of the Frequently Asked Questions about Rule 35d-1 dated December 4, 2001.
If you have any questions regarding the foregoing or need more additional information, please do not hesitate to call me at (617) 295-2565.
Very truly yours,
/s/ Caroline Pearson
Caroline Pearson
Managing Director
Deutsche Investment Management Americas Inc.
cc: John Marten, Esq., Vedder Price P.C.