Securities and Exchange Commission January 2005 – Federal Register Recent Federal Regulation Documents

We are adopting new and amended rules and forms to address comprehensively the registration, disclosure and reporting requirements for asset-backed securities under the Securities Act of 1933 and the Securities Exchange Act of 1934. The final rules and forms accomplish the following: update and clarify the Securities Act registration requirements for asset-backed securities offerings, including expanding the types of asset-backed securities that may be offered in delayed primary offerings on Form S-3; consolidate and codify existing interpretive positions that allow modified Exchange Act reporting that is more tailored and relevant to asset-backed securities; provide tailored disclosure guidance and requirements for Securities Act and Exchange Act filings involving asset-backed securities; and streamline and codify existing interpretive positions that permit the use of written communications in a registered offering of asset-backed securities in addition to the statutory registration statement prospectus. We also request additional comment regarding the appropriate treatment of certain structured securities that do not meet our definition of ``asset-backed security.''

Applicant seeks an order declaring that it has ceased to be an investment company. On September 30, 2004, applicant transferred its assets to Kopp Total Quality Management Fund, a series of Kopp Funds, Inc., based on net asset value. Expenses of $40,700 incurred in connection with the reorganization were paid by Robinson Capital Management, Inc., applicant's former investment adviser. Filing Date: The application was filed on November 17, 2004. Applicant's Address: 7701 France Ave. S, Suite 500, Edina, MN 55435.