THE SCOTT LAW FIRM, P.A.
940 Northeast 79th Street, Suite A
Miami, Florida 33138
(305) 754-3603
facsimile (305) 754-2668
wscott@wscottlaw.com
August 2, 2007
Ms. Linda Van Doorn
Senior Assistant Chief Accountant
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: TriView Global Fund, LLC (the "Fund")
Form 10-K for the year ended 12/31/2006 Filed 4/3/2007
File No. 333-119655
Dear Ms. Van Doorn,
Thank you for the telephone call to afford the Fund notice of the
separate accounting rules available under the Investment Advisors Act of 1940.
Upon review, those rules are unavailable to any commodity pool that wishes to
employ a commodity trading advisor on the terms customary for the industry.
We have reproduced below the Commission's comment provided by your
letter to the Fund of July 19 2007, and have supplied the Fund's response
immediately following it.
FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2006
Note 2 - Significant Accounting Policies
Offering Expenses and Organizational Costs. page F-7
1. We have read your response to comment three. You have recorded a
liability and a corresponding deferred asset representing deferred
organization and offering costs which you have titled "reimbursable
syndication costs", which implies that the company has the right to be
reimbursed for such costs. We maintain our position that your recording of
deferred organization and offering costs as a deferred asset is not in
accordance with GAAP. Please revise your financial statements accordingly to
expense reimbursable organizational costs in accordance with SOP 98-5 and
reflect reimbursable offering costs as a reduction to partnership capital as
of the date of the offering. Refer to SAB Topic SA and 5D. Please note that
you may separately disclose how you are treating these costs for the purposes
of determining net asset value.
Response: The Fund is in the process of revising its financial statements to
expense reimbursable organizational costs in accordance with SOP 98-5 and
reflect reimbursable offering costs as a reduction to Fund capital as of the
date of the offering. The Fund will file these financials within three weeks
from the date of this response as part of Amendment No. 2 to its Form 10-K for
the year ended December 31, 2006.
The Fund became effective November 3, 2005. It requests acceptance of
its restated financials for the affected periods as required to be disclosed
in (1) the 2006 year-end audit to be included in the Form 10-K amendment and
(2) the June 30, 2007 reviewed financials to be included in the second quarter
2007 Form 10-Q. The Fund requests a waiver from the Commission of its
obligation to amend its Form 10-K for the year ended 2005 and Form 10-Q's for
the periods ended March 31, 2006, June 20, 2006, and September 30, 2006. As
you know, the Form 10-Q for the period ended June 30, 2007 is due by August
14, 2007. The Fund requests that it not be required to amend its Form 10-Q
for the period ended March 31, 2007.
The Fund makes these requests because it would be unduly burdensome for
it to amend the above reports, the information will be fully disclosed on the
to-be-filed reports, and it is easier for investors to consider the two to-be-
filed reports than the seven that would be required otherwise. The amended
Form 10-K for the year ended December 31, 2006 and the Form 10-Q for the
period ended June 30, 2007 will disclose that investors should not look to
previously filed reports for financial information.
We are grateful for the opportunity to present this response and are
available to amplify or clarify any information submitted.
Very truly yours,
/s/ William S. Scott
William Sumner Scott
For the Firm
WSS/lf
cc: TriView Capital Management, Inc.
Managing Member - CPO