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

The Sponsor of the CurrencyShares Canadian Dollar Trust requests no-action relief from the certification rules in Exchange Act Rules 13a-14(a) and 15d-14(a) and Item 601(b)(31) of Regulation S-K. The Sponsor, acting on behalf of itself and the Trust, seeks confirmation that the Staff will not recommend enforcement action if Certifications filed with periodic reports, signed by the Sponsor's CEO and CFO, deviate from the standard form. This request addresses the Trust's passive structure where the Trust itself has no employees, officers, or directors, necessitating that the Sponsor's executive officers provide the required certifications.

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M'FOLEY

FOLEY & LARDNER LLP
FOLEY & LARDNER LLP
ATTORNEYS AT LAW
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DETROIT. MI 48226.3469
313,2347100 TEL
313.234.2800 FAX
VIA E-MAIL www.foley.com
CLIENT/MATTER NUMBER
058081.0112
September 6,2006
Securities Exchange Act of 1934
Rules 13a-14(a) and 15d-14(a) and
Item 601(b)(3l) of Regulation S-K

Securities and Exchange Commission

I00 F Street, N.E.

Washington, D.C. 20549

Re: Rydex Specialized Products LLC d/b/a "Rydex Investments", Sponsor of

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