SEC Division of Investment Management staff letter: USAA Mutual Funds Trust

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
INVESTMENT MANAGEMENT
October 22,2008
Diane E. Ambler
K&L Gates LLP
1601K Street, NW
Washington, DC 20006-1600
Re: USAA Mutual Funds Trust -USAA Money Market Fund (File No. 8 1 1-07852) Dear Ms. Ambler:
Based on the facts and representations contained in your September 16,2008 letter, we will not recommend enforcement action to the Securities and Exchange Commission against USAA Mutual Funds Trust -USAA Money Market Fund (the "Fund"), and USAA Property Holdings, Inc. ("PHI" and collectively with its affiliates, the "Purchaser"), under Section 17(a) of the Investment Company Act of 1940, or the rules thereunder, if the Purchaser purchases from the Fund the securities specified in your letter at the amortized cost (including any accrued and unpaid interest) of the securities.' The Fund is a series of USAA Mutual Funds Trust, an open￾end management investment company registered under the Investment Company Act of 1940. USAA Investment Management Company (the "Adviser") is the Fund's investment adviser. PHI and the Adviser are each direct or indirect wholly owned subsidiaries of United Services Automobile Association, and therefore affiliated persons, as defined in Section 2(a)(3) of the Investment Company Act of 1940, of the Fund. We have considered your request for confidential treatment of your letter and our response until January 14,2009 or such earlier date as the Staff of the Division of Investment is advised that all information in your letter has been made public. We have determined that your request is reasonable and appropriate under 17 CFR 200.8 1 (b). Accordingly, your letter and our response will not be made public until January 14,2009. 1 This letter confirms oral no-action relief provided by Robert E. Plaze to Diane E. Ambler on September 16,2008.