January 13, 2023


Via U.S. Mail

Donald Rivers Goolsby
5247 Wilson Mills Road #544
Richmond Heights, Ohio 44143


                      Re:     Donald Rivers Goolsby WHFIT
                              File No. 811-23225

Dear Donald Rivers Goolsby:

        On January 11, 2017 you filed an amended Form N-8A notifying the
Commission of
your intention to register as an investment company under the Investment
Company Act of 1940
(   1940 Act   ). In that filing, you note that you are concurrently filing a
registration statement
pursuant to Section 8(b) of the 1940 Act but the registration statement was not
included with the
filing nor was it later filed.

        As such, your current filing is materially deficient. Consequently, we
believe you should
either deregister the company or amend the filing to provide substantive and
accurate responses
to the Form N-8A item requirements. In that regard, we believe you should
consult with a
lawyer to assist you with the deregistration process or in complying with the
requirements of
Form N-8A.

       As a result of these deficiencies, you should not deem yourself a
registered    investment
company. We do not believe investors should rely on the documents you have
filed with us for
any investment purpose. It is our intention to post this letter.

If you have any questions, you may contact our office at (202) 551-6921.

                                                 Sincerely,


                                                 Disclosure Review and
Accounting Office