SEC Division of Investment Management staff letter: Washington Capital Joint Master Trust

700 5 W I-iflli Avenue. Suile 2500
I'oilland, Orego!l 97204 inaiti 503.224.3380 lax 503.220.2480 www.stoel.co~ii Via Facsimile atzd UPS Douglas J. Scheidt, Esq. Associate Director and Chief Counsel Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Washington Capital Joint Master Trust Dear Mr. Scheidt:
On behalf of our client, Washington Capital Management, Inc., we hereby request that the Staff of the Division of Investment Management (the "Staff") of the Securities and Exchange Commission (the "Commission") confirm that the Staff would not recommend that the Corninission take any enforcement action against Washington Capital Management, Inc, or Bank of New York Trust Company, N.A. if Washington Capital Joint Master Trust (the "Trust") does not register as an investment company under the Investment Company Act of 1940, as amended (the "1940 Act"), under the circumstances described below. We are requesting relief under
Section 7(b) of the 1940 Act.

1. Background
   The Trust is organized as a trust under the laws of the state of Washington and is qualified and tax-exempt as a group trust under the provisions of IRS Revenue Ruling 81-1 00. The Trust's investors are exclusively pension, profit sharing, or other retirement plans qualified under
   Section 401 (a) of the Internal Revenue Code of 1986, as amended (the "Code"), investing
   through trusts that are tax-exempt under Section 501(a) of the Code, government plans,1 and ' The term "government plan" means, in accordance with Code section 401 (a)(24), (i) a governmental plan within the meaning of Code section 414(d), (ii) an eligible deferred compensation plan within the meaning of Code section 457(b), or (iii) the Government of the United States, the government of any State or political subdivision thereof, or any agency or any Oregon Wasliingion Caiiiornia Utah Idaho