May 24, 2006
Mail-Stop 4561
Via facsimile and U.S. Mail
Mr. Carl G. Verboncoeur
Chief Executive Officer and Treasurer
Rydex Investments
9601 Blackwell Road, Suite 500
Rockville, Maryland 20850
Re: CurrencyShares British Pound Sterling Trust (333-
132361)
CurrencyShares Australian Dollar Trust (333-
132362)
CurrencyShares Canadian Dollar Trust (333-
132363)
CurrencyShares Mexican Peso Trust (333-
132367)
CurrencyShares Swedish Krona Trust (333-
132366)
CurrencyShares Swiss Franc Trust (333-132364)
Amendment No. 1 to Forms S-1
Filed May 9, 2006
Dear Mr. Verboncoeur:
We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments. If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.
The purpose of our review process is to assist you in your
compliance with the applicable disclosure requirements and to
enhance
the overall disclosure in your filing. We look forward to working
with you in these respects. We welcome any questions you may have
about our comments or on any other aspect of our review. Feel
free
to call us at the telephone numbers listed at the end of this
letter.
Form S-1
General Comments
1. Make corresponding changes to the other CurrencyShares
documents.
2. Please provide the staff with a copy of the EuroCurrency
listing
agreement with the NYSE.
3. The staff notes that in the absence of a noon buying rate for
the
Federal Reserve Bank of New York, the Trustee, in consultation
with
the Sponsor may change the measuring metric. Please confirm that
in
any instance where the Trustee and Sponsor are required to use
this
power to change the reference metric to determine the daily NAV on
an
other than temporary (one or two day) basis, the new metric will
be
disclosed in a post effective amendment as a fundamental change to
the prospectus.
Report of Independent Registered Public Accounting Firm, page F-2
4. We await the opinion of your independent registered public
accounting firm.
Closing Comments
As appropriate, please amend your registration statement in
response to these comments. You may wish to provide us with
marked
copies of the amendment to expedite our review. Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review. Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.
Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that
* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* the company may not assert this action as defense in any
proceeding
initiated by the Commission or any person under the federal
securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.
We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.
We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement. Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration. Please provide this
request at least two business days in advance of the requested
effective date.
Any questions regarding the accounting comments may be
directed
to Margaret Fitzgerald (202) 551-3556 or Don Walker at (202) 551-
3490. All other questions may be directed to Michael Clampitt at
(202) 551-3434 or to me at (202) 551-3419.
Sincerely,
Christian N. Windsor
Special Counsel
Cc: Patrick Daugherty, Esq.
Foley & Lardner LLP
One Detroit Center
500 Woodard Ave., Suite 2700
Detroit, MI 48226-3489
Mr. Carl G. Verboncoeur
Rydex Investments
Page 1