QUAKER INVESTMENT TRUST
309 Technology Drive
Malvern, PA 19355
610.455.2200
888.220.8888
Fax: 610.455.2222
September 5, 2006
VIA EDGAR AND E-MAIL
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: Linda Stirling
Re: Quaker Investment Trust (the "Registrant")
File Nos. 033-38074 and 811-06260
Ladies and Gentlemen:
Pursuant to the request of our reviewer, Linda Stirling, on behalf of
the staff (the "Staff") of the U.S. Securities and Exchange Commission (the
"SEC"), the Registrant is filing this letter in connection with the filing of
Post-Effective Amendment No. 35 to its Registration Statement on Form N-1A (the
"PEA No. 35") under the Securities Act of 1933, as amended, and the Investment
Company Act of 1940, as amended, which was filed on June 28, 2006. The
Registrant acknowledges that: (i) it is responsible for the adequacy of the
disclosure in PEA No. 35; (ii) Staff comments on PEA No. 35, or changes to PEA
No. 35 in response to Staff comments thereto, do not foreclose the SEC from
taking any action with respect to PEA No. 35; and (iii) the Registrant may not
assert Staff comments as a defense in any proceeding initiated by the SEC under
the federal securities laws of the United States.
In addition, the Registrant acknowledges that the Division of
Enforcement has access to all information that the Registrant has provided to
the Staff of the Division of Investment Management in its review of PEA No. 35.
Sincerely,
/s/Timothy Richards
Timothy Richards
Chief Compliance Officer
Quaker Investment Trust
