FORM 24f-2
Annual Notice of Securities Sold
Pursuant to Rule 24f-2
1. Name and address of issuer:
SwissKey Funds, 6 St. James Avenue
Boston, MA 02116
2. Name of each series or class of funds for which this notice is filed:
SBC Short-Term World Income Fund
SBC World Growth Fund
3. Investment Company Act File Number:811-6333
Securities Act File Number: 33-41091
4. Last day of fiscal year for which this notice is filed:
October 31, 1995
5. Check box if this notice is being filed more than 180 days after the
close of the issuer's fiscal year for the purposes of reporting securities
sold after the close of the fiscal year but before termination of the
issuer's 24f-2 declaration: [ ]
6. Date of termination of issuer's declaration under rule 24f-2(a)(1), if
applicable (see instruction A.6):
7. Number and amount of securities of the same class or series which had been
registered under the Securities Act of 1933 other than pursuant to rule
24f-2 in a prior fiscal year, but which remained unsold at the beginning of
the year:
0
8. Number and amount of securities registered during the fiscal year other
than pursuant to rule 24f-2:
0
9. Number and aggregate sale price of securities sold during the fiscal year:
Series of Registrant Number Sale Price
SBC Short-Term World Income Fund 59,313 $549,141
SBC World Growth Fund 148,920 $2,383,728
10. Number and aggregate sale price of securities sold during the fiscal year
in reliance upon registration pursuant to rule 24f-2:
Series of Registrant Number Sale Price
SBC Short-Term World Income Fund 59,313 $549,141
SBC World Growth Fund 148,920 $2,383,728
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Number and aggregate sale price of securities issued during the fiscal year in
connection with dividend reinvestment plans, if applicable (see Instruction
B.7):
Series of Registrant Number Sale Price
SBC Short-Term World Income Fund 113,403 $1,041,045
SBC World Growth Fund 45,384 $726,400
12. Calculation of registration fee:
(i) Aggregate sale price of securities sold during the fiscal
year in reliance on rule 24f-2 (from Item 10): $2,932,869
(ii) Aggregate price of shares issued in connection with dividend
reinvestment plans (from Item 11, if applicable): +1,767,445
(iii)Aggregate price of shares redeemed or repurchased during
the fiscal year (if applicable): -65,186,586
(iv) Aggregate price of shares redeemed or repurchased and
previously applied as a reduction to filing fees pursuant to
rule 24e-2 (if applicable): +0
(v) Net aggregate price of securities sold and issued during the
fiscal year in reliance on rule 24f-2 [line (i), plus line (ii),
less line (iii), plus line (iv)] (if applicable): -60,486,272
(vi) Divisor prescribed by Section 6(b) of the Securities Act of
1933 or other applicable law or regulation
(see Instruction C.6): 2,900
(vii)Fee due [line (i) or line (v) multiplied by line (vi)]: $ 0.00
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13. Check box if fees are being remitted to the Commission's lockbox depository
as described in section 3a of the Commission's Rules of Informal and Other
Procedures (17 CFR 202.3a).
[ ]
Date of mailing or wire transfer of filing fees to the Commissioner's
lockbox depository:
No fee owed
SIGNATURES
This report has been signed below by the following persons on behalf of the
issuer and in the capacities and on the dates indicated.
By (Signature and Title) ___/s/ David Danielson___________
___Assistant Treasurer___________
Date ___December 26, 1995___
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6 St. James Avenue
Ninth Floor
Boston, Massachusetts 02116
(617) 423-0800
December 26, 1995
SwissKey Funds
6 St. James Avenue, 9th Floor
Boston, Massachusetts 02116
Ladies and Gentlemen:
RE: RULE 24F-2 NOTICE FOR SWISSKEY FUNDS (33-41091) FOR THE FISCAL
YEAR ENDED OCTOBER 31, 1995.
This opinion is being furnished in connection with the registration, pursuant to
Rule 24f-2 under the Investment Company Act of 1940, as amended (the "1940
Act"), of an indefinite number of shares of beneficial interest par value $0.001
per share) (the "Shares") of SBC Short-Term World Income Fund and SBC World
Growth Fund (the "Funds"), two separate seriers of the SwissKey Funds, a
Massachusetts business trust (the "Trust"), under the Securities Act of 1933, as
amended (the "1933 Act"). I understand that the Trust proposes to file a notice
(the "Notice") with the Securities and Exchange Commission (the "Commission")
with respect to the Funds for the fiscal year ended October 31, 1995, pursuant
to such Rule 24f-2 under the 1940 Act. This opinion is being furnished with a
view to your filing it with the Commission in conjunction with the filing of the
Notice.
This opinion is limited solely to the laws of the Commonwealth of Massachusetts
as applied by courts in such Commonwealth. This opinion is limited solely to the
Shares of the Funds as of the fiscal year ended October 31, 1995 as reflected in
the Notice. I understand that the foregoing limitation is acceptable to you.
Based upon and subject to the foregoing, please be advised that it is my opinion
that the Shares covered by the Notice were legally issued and (to the extent
still outstanding) are fully paid and non-assessable, except that, as set forth
in the Fund's registration statement as currently in effect filed with the
Commission pursuant to the 1933 Act, shareholders of the Funds may under certain
circumstances be held personally liable for their respective obligations.
Very truly yours,
/s/ Philip Coolidge
Philip W. Coolidge
