2006-09-06

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SEC Division of Corporation Finance no-action letter: CurrencyShares Australian Dollar Trust

Rydex Specialized Products LLC, sponsor of the CurrencyShares Australian Dollar Trust, requests relief from certification rules under Section 302 of the Sarbanes-Oxley Act and Exchange Act Rules 13a-14(a) and 15d-14(a). The Sponsor seeks confirmation that the Staff will not recommend enforcement action if certifications filed with periodic reports are signed by the Sponsor's CEO and CFO rather than officers of the Trust itself. This request addresses the deviation from the form of Certification set forth in Item 601(b)(31) of Regulation S-K due to the Trust's passive structure and lack of employees.

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