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SEC Comment Letter for AIG Strategic Hedge Fund of Funds (CIK 0001289827) — May 16, 2005

AIG Strategic Hedge Fund of Funds (CIK 0001289827)
Date: May 16, 2005 · CIK: 0001289827 · Accession: 0000000000-05-023891

AI Filing Summary & Sentiment

File numbers found in text: 811-21590

Date
February 1, 2005
Author
Christina L. Delano
Form
UPLOAD
Company
AIG Strategic Hedge Fund of Funds (CIK 0001289827)

Letter

<DESCRIPTION>12B-25 LETTER FEBRUARY 2005 February 1, 2005 Robert Discolo President and Principal Executive Officer AIG Strategic Hedge Fund of Funds 599 Lexington Avenue New York, New York 10022

Re: AIG Strategic Hedge Fund of Funds (the "Registrant") File Number: 811-21590

Dear Mr. Discolo:

We have reviewed the Notification of Late Filing on Form 12b-25 (the "Form") filed December 9, 2004 on behalf of the Registrant related to the Form N-CSRS for the fiscal period ended September 30, 2004.

Based on our review, we have the following comment:

* We have evaluated your response to Part III of the Form and have found your reasons for the extension of time, or lack thereof, to be insufficient.

Based upon the reason(s) stated above, we do not consider the Registrant`s Form N-CSRS to have been filed timely. Additionally, the Registrant did not mail the semi-annual report to stockholders within the time required by Rule 30e-1 under the Investment Company Act of 1940. Rule 30e-1 requires that "each report shall be transmitted within 60 days after the close of the period for which such report is being made". We expect you to discuss these matters, including our letter, with the Registrant`s Board of Directors.

Please respond to each of the points raised in this letter and file your response as EDGAR correspondence. Before you file in response to this letter or file any new information with the Commission, please notify me at (202) 551-6963 so that we may better coordinate our review of your filing/information. Please direct any questions you have regarding this letter to me at the number indicated above or at delanoc@sec.gov.

Sincerely,
Christina L. Delano
Accountant

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>aig.txt
<DESCRIPTION>12B-25 LETTER FEBRUARY 2005
<TEXT>

February 1, 2005

Robert Discolo
President and Principal Executive Officer
AIG Strategic Hedge Fund of Funds
599 Lexington Avenue
New York, New York	10022

Re:	AIG Strategic Hedge Fund of Funds (the "Registrant")
	File Number:  811-21590

Dear Mr. Discolo:

We have reviewed the Notification of Late Filing on Form 12b-25
(the
"Form") filed December 9, 2004 on behalf of the Registrant related
to
the Form N-CSRS for the fiscal period ended September 30, 2004.

Based on our review, we have the following comment:

* We have evaluated your response to Part III of the Form and have
found your reasons for the extension of time, or lack thereof, to
be
insufficient.

Based upon the reason(s) stated above, we do not consider the
Registrant`s Form N-CSRS to have been filed timely.  Additionally,
the Registrant did not mail the semi-annual report to stockholders
within the time required by Rule 30e-1 under the Investment
Company
Act of 1940.  Rule 30e-1 requires that "each report shall be
transmitted within 60 days after the close of the period for which
such report is being made".  We expect you to discuss these
matters,
including our letter, with the Registrant`s Board of Directors.

Please respond to each of the points raised in this letter and
file
your response as EDGAR correspondence.  Before you file in
response
to this letter or file any new information with the Commission,
please notify me at (202) 551-6963 so that we may better
coordinate
our review of your filing/information.  Please direct any
questions
you have regarding this letter to me at the number indicated above
or
at delanoc@sec.gov.

Sincerely,

Christina L. Delano
Accountant

cc:	Frank Donaty
	Assistant Director
	Division of Investment Management
	U.S. Securities and Exchange Commission

	Louis P. Becka
	Assistant Director
	Office of Compliance Inspections and Examinations
	U.S. Securities and Exchange Commission

	Brian D. Bullard
	Chief Accountant
	Division of Investment Management
	U.S. Securities and Exchange Commission

</TEXT>
</DOCUMENT>