[Letterhead of Puglisi & Associates]
August 26, 1999
Securities and Exchange Commission
Attn: Ajay Mehra
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: BCD HITS Trust
Registration Statement on
Form N-2, File No. 333-24731
----------------------------
Dear Mr. Mehra:
Pursuant to Rule 477 of the Securities Act of 1933, BCD HITS Trust, a
Delaware business trust (the "Trust") hereby requests the withdrawal of its
Registration Statement on Form N-2, File No. 333-24731, originally filed with
the Securities and Exchange Commission (the "Commission") on April 8, 1997. The
withdrawal is based on a request made by the Commission to withdraw the
Registration Statement.
In addition to filing this request under the EDGAR system, this letter
will also be faxed to your attention. Acknowledgment will occur via the E-mail
address provided with the EDGAR filing as well as faxed transmission acceptance
to the Trust. If you have any questions with respect to this matter, please
call either Jim Rothwell of Davis Polk & Wardwell at (212) 450-4806 or
Christopher Cooper of the same firm at (212) 450-6102.
Very truly yours,
/s/ Donald J. Puglisi
- ---------------------------
Donald J. Puglisi
Trustee
BCD HITS Trust
Trust's Telephone Number:
(302) 738-6680
Trust's Facsimile Number:
(302) 738-7210
cc: J. Rothwell, Davis Polk & Wardwell
C. Cooper, Davis Polk & Wardwell
