[SRSY LOGO]
2600 One Commerce Square
Philadelphia, PA 19103-7098
T: (215) 564-8099
F: (215) 564-8120
September 6, 2006
Via EDGAR and E-mail
Linda Stirling
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Re: Quaker Investment Trust
File Nos. 033-38074 and 811-06260
Dear Ms. Stirling:
On behalf of the Quaker Investment Trust (the "Registrant"), the
following are our responses to the comments of the staff (the "Staff") of the
U.S. Securities and Exchange Commission (the "SEC") conveyed with respect to
Post-Effective Amendment No. 35 to the Registrant's Registration Statement on
Form N-1A, which was filed on June 28, 2006 pursuant to Rule 485(a) under the
Securities Act of 1933, as amended, to register a new series, the Quaker Global
Growth Fund (the "Fund"). Each Staff comment is summarized below, followed by
the Registrant's response to the comment.
1. Comment. In the second bullet point under the "Principal Investment
Strategy" section of the Fund's prospectus, identify the methodology that the
Fund's sub-adviser will use to identify companies that have a probability for
superior growth prospects.
Response. The Registrant will add the following disclosure at the end
of the second bullet under the "Principal Investment Strategy" section: "The
Fund's sub-adviser seeks to identify such companies by using a "bottom up"
approach, i.e., by focusing on individual companies rather than on short-term
movements in broad economic factors, such as interest rates or commodity
prices."
2. Comment. The fourth bullet point under the "Principal Investment
Strategy" section of the Fund's prospectus states that the Fund may invest up to
50% of its total assets in special situations. Under the "Principal Risks"
section of the prospectus, it states that the Fund may invest up to 25% of its
total net assets in special situations. Clarify to what extent the Fund may
invest in special situations, and whether such percentage limitation is based on
total or net assets.
Response. The actual limitation on the Fund's investments in special
situations will be 20% of its total assets. The disclosure in the "Principal
Investment Strategy" and "Principal Risks" sections of the Fund's prospectus
will be revised accordingly.
3. Comment. Under the "Principal Risks" section of the Fund's prospectus,
explain that one of the risks of portfolio turnover is higher costs.
Response. The portfolio turnover risk disclosure will be revised as
follows:
The Fund's portfolio manager may engage in aggressive portfolio
trading. As a result, the Fund could experience higher than average
portfolio turnover. A high rate of portfolio turnover in any year may
increase brokerage commissions paid and could generate greater taxes
for shareholders on realized investment gains.
4. Comment. The liquidity risk disclosure under the "Principal Risks"
section of the Fund's prospectus states that the Fund will not invest more than
10% of its net assets in illiquid securities. Does the 10% limitation include
investments in special situations?
Response. As previously noted, the Fund may not invest more than 20%
of its total assets in special situation investments; however, not all special
situation investments will involve illiquid securities. To the extent such
investments involve securities that cannot readily be sold within seven days at
approximately the price at which they are valued, they will be considered
illiquid and fall within the Fund's illiquid securities limitation.
5. Comment. The expense examples are not consistent with the stated
ratios in the fee table. Provide the correct expense example numbers.
Response. The expense examples will be revised as indicated below:
If you redeem your shares at the end of the period, your expenses for
investing in the Fund would be:
One Year Three Years
Class A $793 $1,297
Class C $432 $1,013
If you did not redeem your shares at the end of the period, your
expenses for investing in the Fund would be:
One Year Three Years
Class A $793 $1,297
Class C $332 $1,013
6. Comment. If the Registrant believes that the Fund's portfolio turnover
will significantly exceed 100% annually, the disclosure under the "Portfolio
Turnover" section should be revised.
Response. Until the Fund commences operations and the sub-adviser
begins managing the Fund's portfolio, the Registrant cannot predict whether the
Fund's annual portfolio turnover rate will significantly exceed 100% annually.
As a result, the Registrant intends to leave the current disclosure unchanged,
but will monitor the Fund's portfolio turnover once it commences operations and
will revise the prospectus disclosure as necessary if the portfolio turnover
rate significantly exceeds 100%.
7. Comment. Under the "Management of the Fund" section of the Fund's
prospectus, provide more detailed information about the portfolio managers'
business experience during the past five years as required by Item 5(a)(2) of
Form N-1A.
Response. The "Sub-Adviser and Portfolio Managers" section of the
Fund's prospectus will be revised as follows:
Manu Daftary and Chris Perras are primarily responsible for the
day-to-day management of the Fund. Messrs. Daftary and Perras have
been the Fund's portfolio managers since its inception. Mr. Daftary
has primary responsibility for the investments of the Fund and has
final authority over all aspects of the Fund's investment portfolio,
including but not limited to, purchase and sale of individual
securities, portfolio risk assessment, and the management of daily
cash balances in accordance with anticipated management requirements.
Mr. Perras provides research and advice on the purchase and sale of
individual securities, and portfolio risk assessment.
Manu Daftary, CFA-- President and Chief Investment Officer of DG
Capital. Mr. Daftary founded DG Capital in 1996. Prior to founding DG
Capital, he served as a portfolio manager at several investment
management firms. Mr. Daftary holds a BA in economics from the
University of Mumbai, India and a BS and MBA from California State
University at Long Beach. He is a Chartered Financial Analyst.
Chris Perras, CFA-- Portfolio Manager. Mr. Perras joined DG Capital in
June 2002. From April 1999 to June 2002, Mr. Perras was part of a
management team at AIM Capital Management that was responsible for the
AIM Opportunities Long/ Short funds and AIM's hedge fund products. He
received a BS in electrical engineering from the Georgia Institute of
Technology and a MBA from Harvard Graduate School of Business
Administration. He is a Chartered Financial Analyst.
8. Comment. Why is there different disclosure with respect to the
valuation of individual securities and foreign securities under the "Fair
Valuation" section of the prospectus? Is there a different process for fair
valuing foreign securities?
Response. The Registrant has included additional disclosure about the
valuation of foreign securities to explain that the foreign securities held by
the Fund may be valued before the close of the foreign exchange on which they
are traded because the New York Stock Exchange ("NYSE") closes prior to the
foreign exchange's closing time. An additional purpose for including the foreign
securities fair valuation disclosure is to explain that a foreign security's
value is converted into U.S. dollars based on the applicable foreign exchange
rate. However, to the extent that a foreign security must be fair valued, the
Registrant's Valuation Committee uses the same process for valuing domestic and
foreign securities. Accordingly, the Fund's foreign securities fair valuation
disclosure will be revised as follows to clarify that this is the Fund's
practice:
Foreign Securities. The value of a foreign security is generally
determined as of the close of trading on the foreign stock exchange on
which the security is primarily traded, or as of the close of trading
on the NYSE, if earlier. The value is then converted into its U.S.
dollar equivalent at the foreign exchange rate in effect at the close
of the NYSE (generally 4:00 p.m. Eastern time) on the day that the
value of the foreign security is determined. If no sale is reported at
that time, the foreign security will be valued within the range of the
most recent quoted bid and ask prices. If a market quotation is not
readily available for a foreign security or an event has occurred that
has caused a quotation to be unavailable or unreliable, the Valuation
Committee will fair value foreign securities using the procedures
described above.
9. Comment. On the back cover of the Fund's prospectus under "How To Get
More Information, it states that additional information about the Fund is
available in the Trust's latest annual report dated June 30, 2006. However, the
Fund will not be effective or commence operations until after June 30, 2006.
Revise the disclosure accordingly.
Response. The disclosure will be revised as follows: "Additional
information about the Fund is available in the Trust's latest Audited
Annual Report dated December 31, 2006, and its Statement of Additional
Information."
* * *
Please do not hesitate to contact me at the above number if you have
any questions or wish to discuss any of the responses presented above.
Sincerely yours,
/s/Jonathan M. Kopcsik
Jonathan M. Kopcsik
cc: Timothy Richards, Esq.
Alan Gedrich, Esq.
