[STRADLEY RONON LOGO] Stradley Ronon Stevens & Young, LLP 1220 19th Street, NW Suite 600 Washington, DC 20036 Telephone (202) 822-9611 Fax (202) 822-0140 March 20, 2006 VIA Edgar and Email Linda B. Stirling Division of Investment Management U.S. Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re: Quaker Investment Trust (File Nos. 033-38074 and 811-6260) - Response to SEC Comments on Preliminary Proxy Statements Dear Ms. Stirling: I am responding to your comments, provided via telephone to me related to the two preliminary proxy statement filings made by Quaker Investment Trust (the "Trust") on Schedule 14A on March 10, 2006. As you know, a separate preliminary proxy statement was filed for use in soliciting the vote of shareholders to approve the liquidation of the Quaker Fixed Income Fund and the Quaker Small-Cap Trend Fund (each, a "Fund"). Please note that the changes to disclosure indicated below will be made in the definitive proxy statements to be filed by the Trust related to these matters. Your comment and our response to it are set forth below. In connection with our response to your comment, we acknowledge, on behalf of the Trust and each Fund, that: o Each Fund is responsible for the adequacy and accuracy of the disclosure in the filing; o Staff comments or changes to disclosure in response to staff comments in the filing reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and o Each Fund may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Linda B. Stirling March 20, 2006 Page 2 of 2 Comment: Please include the disclosure required by Item 6(d) of Schedule 14A in the proxy statement for each Fund. Response: We have added disclosure to Exhibit C in the respective proxy statement as follows to address your comment: For the Quaker Fixed Income Fund: "As of February 28, 2006, all Trustees and Officers of the Quaker Fixed Income Fund as a group owned beneficially or of record less than 1% of each Class of the Quaker Fixed Income Fund." For the Quaker Small-Cap Trend Fund: "As of February 28, 2006, all Trustees and Officers of the Quaker Small-Cap Trend Fund as a group owned beneficially or of record less than 1% of each Class of the Quaker Small-Cap Trend Fund except as follows: 90.08% of the Class I shares." * * * Should you have any questions or concerns regarding any of the above, please contact me at (202) 419-8417. Best Regards, /s/ Prufesh R. Modhera Prufesh R. Modhera, Esq. cc: Tim Richards Alan Gedrich Chris Zimmerman
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CORRESP Filing
Quaker Investment Trust CORRESPCorrespondence with SEC
Filed: 20 Mar 06, 12:00am