SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Comment Letter for CAMPBELL ALTERNATIVE ASSET TRUST (CIK 0001114485) — Dec 13, 2005

CAMPBELL ALTERNATIVE ASSET TRUST (CIK 0001114485)
Date: Dec. 13, 2005 · CIK: 0001114485 · Accession: 0000000000-05-062131

AI Filing Summary & Sentiment

File numbers found in text: 333-74014

Date
December 13, 2005
Author
Michael McTiernan
Form
UPLOAD
Company
CAMPBELL ALTERNATIVE ASSET TRUST (CIK 0001114485)

Letter

Mail Stop 4561 December 13, 2005 Theresa D. Becks Campbell & Company, Inc. Court Towers Building 210 West Pennsylvania Avenue Towson, Maryland 21204

Re: Campbell Alternative Asset Trust Post-Effective Amendment No. 5 to Form S-1 Registration No. 333-74014 Filed on December 5, 2005

Dear Ms. Becks:

This is to advise you that we have performed a limited review of the above registration statement and have the following comments. We will not conduct any further review of the registration statement, except for any amendments you file in response to our comments.

Undertakings

1. Please update your Item 512(a) undertakings in accordance with the amendments thereto that became effective as of December 1, 2005.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Act of 1933 and that they have provided all information investors require for an informed investment 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 staff comments and the declaration of effectiveness as a 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 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.

If you have any questions, please call David H. Roberts at (202) 551-3856 or the undersigned at (202) 551-3852.

Sincerely,
Michael McTiernan
Special Counsel

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

      Mail Stop 4561
      December 13, 2005

Theresa D. Becks
Campbell & Company, Inc.
Court Towers Building
210 West Pennsylvania Avenue
Towson, Maryland 21204

Re:	Campbell Alternative Asset Trust
      Post-Effective Amendment No. 5 to Form S-1
      Registration No. 333-74014
      Filed on December 5, 2005

Dear Ms. Becks:

      This is to advise you that we have performed a limited
review
of the above registration statement and have the following
comments.
We will not conduct any further review of the registration
statement,
except for any amendments you file in response to our comments.

Undertakings

1. Please update your Item 512(a) undertakings in accordance with
the
amendments thereto that became effective as of December 1, 2005.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment 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 staff comments and the declaration
of
effectiveness as a 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 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.

      If you have any questions, please call David H. Roberts at
(202) 551-3856 or the undersigned at (202) 551-3852.

      Sincerely,

      Michael McTiernan
      Special Counsel

cc:	Michael J. Schmidtberger, Esq. (via facsimile)

??

??

??

??

Theresa D. Becks
December 13, 2005
Page 1

</TEXT>
</DOCUMENT>