CENTURY CAPITAL MANAGEMENT, LLC
100 Federal Street, 29th Floor
Boston, MA 02110
BY EDGAR
July 12, 2005
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Attention: Kevin Rupert
Re: Century Capital Management Trust (File Nos. 333-86067 and 811-09561)
Dear Mr. Rupert:
On behalf of Century Capital Management Trust (the "Trust"), I am writing to
respond to the staff's comments made to me by telephone on July 11, 2005
relating to the Trust's Certified Shareholder Report on Form N-CSR for the
period ended October 31, 2004, which was filed with the Securities and Exchange
Commission ("SEC") on January 7, 2005. Set forth below is a summary of the
comments communicated to me via telephone and the Trust's responses thereto.
Comments:
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You advised me that, following your review of the Trust's financial statements,
you checked the Trust's website and noted that a Supplement dated January 6,
2005 to the Trust's Annual Report for the fiscal year ended October 31, 2004
(the "Annual Report") was posted on the website. The Supplement provides a
corrected Shareholder Expense Example table for Century Small Cap Select Fund
(the "Fund"), a series of the Trust, replacing the table that appears on page 6
of the Annual Report. You noted that an amended Form N-CSR was not filed to
reflect the corrected expense information. You asked that I confirm whether Fund
shareholders received the corrected expense information.
Response:
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The Annual Report was mailed to shareholders of the Trust on December 30, 2004.
On January 6, 2005, it was determined that certain information set forth in the
Shareholder Expense Example table for the Fund was incorrect. Specifically, the
ending account values and the expenses paid during the reporting period for the
Fund's two share classes (the Institutional Shares and the Investor Shares) had
been inadvertently reversed. As a result, for the Fund's Institutional Shares,
the ending account value was understated slightly and the expenses paid during
the reporting period were overstated. For the Fund's Investor Shares, the ending
account value was overstated by $2.08 (or 0.201%) based on actual return and
$1.71 (or 0.168%) based on a hypothetical return of 5%, and the expenses paid
during the reporting period were understated by $1.78 based on actual return and
$1.77 based on the hypothetical return.
As noted above, a Supplement to the Annual Report, correcting the table, was
printed and posted on the Trust's website on January 6, 2005, the day the error
was discovered, and was attached to the Annual Report distributed after that
date. We have confirmed that no prospective investors received the incorrect
expense information. However, the Supplement was not mailed to the Fund's
existing shareholders and an amended Form N-CSR was not filed to reflect the
corrected expense information.
Upon review of this matter, we recognize that an amended Form N-CSR should have
been filed to reflect the corrected Shareholder Expense Example table. To
address this matter, the Trust will file today an amended Form N-CSR with the
required certifications. In regards to any confusion that may have resulted from
this error for the Fund's existing shareholders, we note that the Trust's
Semi-Annual Report for the fiscal period ending April 30, 2005, which contains
complete and correct information in the Shareholder Expense Example table for
the Fund, was mailed to shareholders on June 24, 2005. Finally, please be
advised that we are reviewing the Trust's procedures in light of this matter and
will make appropriate changes, in particular, to provide for timely corrective
action in the future should a similar matter occur.
* * * * *
I have been authorized by the Trust to acknowledge that (1) the Trust is
responsible for the adequacy and accuracy of the disclosure in the filing; (2)
comments by the staff or changes to the disclosure in response to staff comments
on the filings reviewed by the staff do not foreclose the SEC from taking any
action with respect to the filing; and (3) the Trust may not assert staff
comments as a defense in any proceeding initiated by the SEC or any person under
the federal securities laws of the United States. As indicated in the SEC's June
24, 2004 release regarding the public release of comment letters and responses,
you are requesting such acknowledgements from all companies whose filings are
being reviewed, and this request and these acknowledgements should not be
construed as suggesting that there is an inquiry or investigation or other
matter involving the Trust.
I believe that this letter addresses the SEC staff's comments. Should you have
any further questions, please do not hesitate to call me at 617-482-3060. Thank
you for your assistance.
Very truly yours,
/s/ Maureen E. Kane
Maureen E. Kane
cc: Michelle M. Kelley