INGENUITY CAPITAL TRUST
N-18F1, 1999-07-14
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                                  Form N-18F-1

                       SECURITIES AND EXCHANGE COMMISSION

                            Washington, D.C.  20549

NOTIFICATION OF ELECTION PURSUANT TO RULE 18f-1 UNDER THE INVESTMENT COMPANY ACT
OF 1940.

                            Ingenuity Capital Trust
- --------------------------------------------------------------------------------
                            Exact Name of Registrant

                            NOTIFICATION OF ELECTION

     The undersigned registered open-end investment company hereby notifies the
Securities and Exchange Commission that it elects to commit itself to pay in
cash all redemptions by a shareholder of record as provided by Rule 18f-1 under
the Investment Company Act of 1940.  It is understood that this election is
irrevocable while such Rule is in effect unless the Commission by order upon
application permits the withdrawal of this Notification of Election.

                                   SIGNATURE

     Pursuant to the requirements of Rule 18f-1 under the Investment Company Act
of 1940, the registrant has caused this notification of election to be duly
executed on its behalf in the city of Milwaukee and the state of Wisconsin on
the 14th day of July, 1999.

                              Signature  Ingenuity Capital Trust
                                         --------------------------------------
                                          (Name of Registrant)

                              By: /s/ Kendrick W. Kam
                                  ---------------------------------------------
                                       Kendrick W. Kam
                                       (Name of director, trustee or officer
                                       signing on behalf of Registrant)

                              President
                              -------------------------------------------------
                                  (Title)

Attest: /s/Elaine E. Richards
        --------------------------
           Elaine E. Richards

        Assistant Secretary
        --------------------------
             (Title)



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