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BINGHAM DANA LLP
150 FEDERAL STREET
BOSTON, MASSACHUSETTS 02110-1726
May 5, 1999
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: CGM Capital Development Fund
Registration Statement on Form N-1A
(File Nos. 2-16252 and 811-933)
Ladies and Gentlemen:
Pursuant to Rule 497(j) under the Securities Act of 1933, as amended,
CGM Capital Development Fund, a Massachusetts business trust (the "Trust"),
hereby certifies that the forms of the Prospectus and Statement of Additional
Information that would have been filed by the Trust pursuant to Rule 497(c) upon
the effectiveness of Post-Effective Amendment Number 65 to the Trust's
registration statement on Form N-1A (the "Amendment") would not have differed
from those contained in the Amendment. The Amendment, which was filed via the
EDGAR system on April 30, 1999, is the most recent amendment to the Trust's
registration statement relating to the Trust.
Please call the undersigned at (617) 951-8383 or Jeremiah J. Bresnahan,
Jr. at (617) 951-8724 or Thomas John Holton at (617) 951-8587, with any
questions relating to this letter.
Sincerely,
Jennifer H. Hurford
