----------------------------
[LOGO] CLEARWATER INVESTMENT TRUST
----------------------------
1145 BROADWAY, SUITE 1500
P.O. BOX 1278
TACOMA, WASHINGTON 98401
(253) 272-8336
June 21, 2007
Ms. Christina DiAngelo
Senior Staff Accountant
U.S. Securities and Exchange Commission
Division of Investment Management
Office of Disclosure and Review
100 F. Street, NE
Washington, DC 20549-4720
Re: Clearwater Investment Trust (Investment Company File Number 811-05038)
Dear Ms. DiAngelo:
This letter is in response to our phone conversation of June 4, 2007 regarding
the Clearwater Investment Trust. The following describes the actions that have
been taken, or are currently being taken by the management of the Trust in order
to comply with your comments. Our responses are set forth in the order that they
were discussed during the phone conversation.
Item I and II Form N-CSR
You noted that the Form N-CSR for the year-ending December 31, 2006 appears to
be missing Items 2 through 12. You also noted that the certification that was
used for this filing did not include the most recent wording. We have reviewed
the filing and agree that these items were missing. The missing information will
be incorporated into an amended Form N-CSR that will be filed shortly. The
certification has also been updated and will also be incorporated into the
amended filing.
Items III, IV and V Form N-CSR
You requested that additional wording be added as a footnote to the table of
trustees regarding the availability of additional information about the Fund
directors. The following statement will be listed as a footnote in the next
filing.
Additional information about the Fund Directors is available in the Fund's
Statement of Additional Information (SAI). The SAI is available, without
charge, upon request, by contacting the transfer agent at (888) 228-0935
or writing the funds at 2000 Wells Fargo Place, 30 East 7th Street, St.
Paul, Minnesota 55101-4930. The funds do not have an Internet Web site.
You noted that the Statement of Assets and Liabilities lists "Investments in
uncollectible securities" and questioned the use of the term "uncollectible." We
have reviewed this and will remove this term in the next filing.
You noted that footnote (2)(a) in the Notes to the Financial Statements should
include enhanced fair value pricing language, similar to what is included in the
Prospectus and SAI. We will include enhanced language in the next filing.
Item VI Form N-Q
You noted that one of the Schedule of Investments noted it was unaudited but the
other two funds did not have such a notation. We will make sure to note in
future filings whether the Schedule of Investments is either audited or
unaudited.
Item VII Form NSAR
You noted that the Report of Independent Registered Public Accounting Firm did
not include the city and state next to the date. We will make sure that the city
and state are noted on all future filings.
Item VIII Form 40-17G
You noted that the fidelity bond filing did not include an approved resolution
by the Board of Trustees. The Board of Trustees approved the change in the bond
at their meeting of September 8, 2006. An amended filing will be done shortly to
include an approval resolution.
Clearwater Investment Trust and the Board of Trustees take their responsibility
for the Trust's compliance with the rules and regulations of the Investment
Company Act of 1940 very seriously. The fund is responsible for the adequacy and
accuracy of the disclosure in the filings and any SEC staff comments or changes
to disclosure in response to SEC staff comments in the filings reviewed by the
staff do not foreclose the Commission from taking any action with respect to the
filing. In addition, the fund acknowledges that it may not assert SEC staff
comments as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.
If you have any questions or need additional information concerning the above
matters, please contact me at 651-215-4428 or Sue Smith at 651-215-4436.
Very truly yours,
/s/ Jay A. Narverud
Jay A. Narverud
Chief Compliance Officer
Clearwater Investment Trust
cc: George H. Weyerhaeuser, Jr.
2