Iowa Public Agency Investment Trust Inactive
Filed: 16 Nov 09, 12:00am
November 16, 2009
United States Securities & Exchange Commission
100 F Street, N.E.
Washington, DC 20549-5631
| Re: | Iowa Public Agency Investment Trust |
| Reg. No. 811-07696 |
| Preliminary Proxy Statement filed October 29, 2009 |
Ladies and Gentlemen,
Please direct all further comments regarding post effective amendments, proxy statements or other filings to the undersigned.
The Definitive Proxy Statement filed today includes revisions responsive to your telephone comments received November 10, 2009.
Your comments included the following:
| • | Add a statement that WB Capital Management, Inc. is also the Administrator to IPAIT and assure that its address is included. |
| • | Put in bold face the last paragraph on the 1st page relating to the availability of annual and semi-annual reports. |
| • | Revise the headings to and the disclosure about the Current and New Advisor Agreements. |
| • | Reference the Board’s consideration of performance in approving the New Advisor Agreement. |
We agree that the Iowa Public Agency Investment Trust is responsible for the adequacy and accuracy of the disclosure in its filings; that staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Securities and Exchange Commission from taking any action with respect to the filing; and the Iowa Public Agency Investment
November 16, 2009
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Trust may not assert staff comments as a defense in any proceeding initiated by the Securities and Exchange Commission or any other person under the federal securities laws of the United States.
| Sincerely, |
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| John C. Miles |
| For the Firm |