February 22, 1994
Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
Re: Rule 24f-2 Notice for
T. Rowe Price International Funds, Inc.
T. Rowe Price International Bond Fund
T. Rowe Price Global Government Bond Fund
T. Rowe Price Short-Term Global Income Fund
100 East Pratt Street
Baltimore, Maryland 21202
File Number 2-65539
Gentlemen:
In accordance with the provisions of Rule 24f-2, the T. Rowe Price
International Funds, Inc. hereby files its Rule 24f-2 Notice on behalf of
its T. Rowe Price International Bond Fund ("Bond Fund"), T. Rowe Price
Global Government Bond Fund ("Global Government Bond Fund") and T. Rowe
Price Short-Term Global Income Fund ("Short-Term Global Income Fund").
This "Rule 24f-2 Notice" is being filed for the Fiscal Year ended
December 31, 1993 for the Bond, Global Government Bond and Short-Term
Global Income Funds.
No shares of common stock for the Bond Fund, which have been
registered under the Securities Act of 1933 (other than pursuant to Rule
24f-2), remained unsold at the beginning of the Fiscal Year.
35,266,293, 2,189,507 and 15,118,097 shares of common stock of the
Bond, Global Government Bond and Short-Term Global Income Funds,
respectively, were sold during the Fiscal Year.
All 35,266,293, 2,189,507 and 15,118,097 shares of common stock of
the Bond, Global Government Bond and Short-Term Global Income Funds,
respectively, were sold during the Fiscal Year in reliance upon the
Declaration of an indefinite amount of securities under Rule 24f-2 ("24f-2
Declaration").
<PAGE>
Attached to this Rule 24f-2 Notice, and made a part hereof, is an
opinion of counsel indicating that the securities, the registration of
which the Notice makes definite in number, were legally issued, fully
paid, and non-assessable.
In accordance with subsection (c) of Rule 24f-2, the registration
fees in the amounts of $46,757.49 and $8,927.41 for the Bond and Short-
Term Global Income Funds, respectively, have been forwarded to Mellon
Bank, Pittsburgh, Pennsylvania. No fee is due for the Global Government
Bond Fund. The fee computations are based upon the actual aggregate sale
price for which such securities were sold during the Fiscal Year, reduced
by the difference between:
(1) The actual aggregate redemption price of the shares
redeemed by the Fund during the Fiscal Year, and
(2) The actual aggregate redemption price of such
redeemed shares previously applied by the Fund
pursuant to Rule 24e-2(a) in filings made pursuant
to Section 24(e)(1) of the Investment Company Act of
1940.
<PAGE>
Bond Global Gov't
Fund Bond Fund
Aggregate Sale Price
for Shares Sold
During Fiscal Year
in Reliance Upon
the 24f-2 Declaration $366,342,622 $ 22,506,307
Reduced by the
Difference Between
(1) Aggregate Redemption
Price of Shares
Redeemed During
the Fiscal Year $230,746,864 $ 32,052,798
and,
(2) Aggregate Redemption
Price of Redeemed Shares
Previously Applied by
Fund Pursuant to
Rule 24e-2(a) Filings
Made Pursuant to Section
24(e)(1) of Investment
Company Act of 1940 $ - 0 - $ - 0 -
Equals $135,595,758 ($ 9,546,491)
<PAGE>
Short-Term
Global
Income
Fund
Aggregate Sale Price
for Shares Sold
During Fiscal Year
in Reliance Upon
the 24f-2 Declaration $ 72,690,834
Reduced by the
Difference Between
(1) Aggregate Redemption
Price of Shares
Redeemed During
the Fiscal Year $ 46,801,517
and,
(2) Aggregate Redemption
Price of Redeemed Shares
Previously Applied by
Fund Pursuant to
Rule 24e-2(a) Filings
Made Pursuant to Section
24(e)(1) of Investment
Company Act of 1940 $ - 0 -
Equals $ 25,889,317
Any questions regarding the matter should be addressed
to Henry H. Hopkins, Esquire at the above address.
Very truly yours,
/s/ CARMEN F. DEYESU
February 22, 1994
T. Rowe Price International Funds, Inc.
100 East Pratt Street
Baltimore, Maryland 21202
Dear Sirs:
T. Rowe Price International Funds, Inc., a Maryland corporation (the
"Corporation"), on behalf of certain of its designated series, T. Rowe
Price International Bond Fund (the "Bond Fund"), T. Rowe Price Global
Government Bond Fund (the "Global Government Bond Fund") and T. Rowe Price
Short-Term Global Income Fund (the "Short-Term Global Income Fund") is
filing with the Securities and Exchange Commission a Rule 24f-2 Notice
containing the information specified in paragraph (b)(1) of Rule 24f-2
under the Investment Company Act of 1940 (the "Rule"). The effect of the
Rule 24f-2 Notice, when accompanied by this Opinion and by the filing fee,
if any, payable as prescribed by paragraph (c) of the Rule will be to make
definite in number the number of shares sold by the Bond Fund, the Global
Government Bond Fund and the Short-Term Global Income Fund during the
fiscal year ended December 31, 1993 in reliance upon the Rule (the "Rule
24f-2 Shares").
We have, as counsel, participated in various corporate and other
proceedings relating to the Corporation and to the Rule 24f-2 Shares. We
have examined copies, either certified or otherwise proven to our
satisfaction to be genuine, of its Charter and By-Laws, as currently in
effect, and a certificate dated February 3, 1994 issued by the Department
of Assessments and Taxation of the State of Maryland, certifying the
existence and good standing of the Corporation. We have also reviewed the
Corporation's Registration Statement on Form N-1A and the form of the Rule
24f-2 Notice being filed by the Corporation. We are generally familiar
with the corporate affairs of the Corporation.
The Corporation has advised us that the Rule 24f-2 Shares were
sold in the manner contemplated by the prospectus that was current and
effective under the Securities Act of 1933 at the time of sale, and that
the Rule 24f-2 Shares were sold in numbers within the limits prescribed by
the Charter of the Corporation and that the Corporation received with
respect to the Rule 24f-2 Shares consideration in an amount of not less
than the par value thereof as required by the laws of Maryland and not
less than the net asset value thereof as required by the Investment
Company Act of 1940.
<PAGE>
Based upon the foregoing, it is our opinion that:
A. The Corporation has been duly organized and is legally
existing under the laws of the State of Maryland.
B. The Corporation is authorized to issue one billion
(1,000,000,000) shares of capital stock, par value one cent ($0.01) per
share. Under Maryland law (a) the number of authorized shares may be
increased or decreased by action of the Board of Directors and (b) shares
which were issued and which have subsequently been redeemed by the
Corporation are by virtue of such redemption, restored to the status of
authorized and unissued shares.
C. The Rule 24f-2 Shares were legally issued and are fully paid
and non-assessable.
We hereby consent to the filing of this Opinion with the
Securities and Exchange Commission together with the Rule 24f-2 Notice of
the Corporation, and to the filing of this Opinion under the securities
laws of any state.
We are members of the Bar of the State of New York and do not
hold ourselves out as being conversant with the laws of any jurisdiction
other than those of the United States of America and the State of New
York. We note that we are not licensed to practice law in the State of
Maryland, and to the extent that any opinion herein involves the law of
the State of Maryland, such opinion should be understood to be based
solely upon our review of the documents referred to above, the published
statutes of the State of Maryland and, where applicable, published cases,
rules or regulations of regulatory bodies of that State.
Very truly yours,
/s/ Shereff, Friedman, Hoffman & Goodman
