SEC Division of Investment Management staff letter: College and University Facility Loan Trust One, et al.

College and University Facility Loan Trust One and Trust Two request that the Division of Investment Management confirm it will not recommend enforcement action if the Trusts file modified certifications under Section 30 of the Investment Company Act and Rule 30a-2 for semi-annual Form N-CSR and quarterly Form N-Q reports. The Trusts seek relief from maintaining disclosure controls and procedures or internal control over financial reporting as defined in Rule 30a-3, arguing their structure resembles asset-backed issuers. The request requires the Trusts to file specific modified certifications and attach annual compliance statements from servicers and attestation reports from independent accountants as exhibits to their periodic filings.

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Re: Amended and Restated No-Action Letter Request College and University Facility Loan Trust One (File No. 811-05291) College and University Facility Loan Trust Two (File No. 811-05506) Sarbanes Oxley Act of 2002: Section 302 Investment Company Act: Section 30 Investment Company Act: Rules 30a-2, 30a-3 and 30b2-1

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