Investment Company Act of 1940 — Section 15(a)

April 15, 2019

Response of the Chief Counsel’s Office
Division Of Investment Management

Your letter dated April 12, 2019 (“Letter”) requests our assurance that we would not recommend enforcement action to the Commission against Community Capital Management, Inc. (“CCM”) or Camelot Portfolios, LLC (together with CCM, the “Advisers”) under Section 15(a) of the Investment Company Act of 1940 (the “1940 Act”) if, under the circumstances described in your Letter, the Advisers continued to serve as investment advisers to certain series of the Quaker Investment Trust (the “Trust”) for a limited period of time pursuant to written investment advisory agreements that were not approved by the vote of a majority of the outstanding voting securities of such series.[1]

Based on the facts and representations in your Letter, we would not recommend enforcement action to the Commission under Section 15(a) of the 1940 Act if the Advisers continued to serve as investment advisers to such series of the Trust as discussed above.

The statements in this letter represent the views of the Division of Investment Management. This letter is not a rule, regulation or statement of the Commission, and the Commission has neither approved nor disapproved its content.

Jill Ehrlich
Senior Counsel