RULE 24F-2 NOTICE
SECURITIES AND EXCHANGE COMMISSION
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
RE: Rule 24F-2 Notice for Capital Value Fund, Inc.,
Equity Portfolio-Initial Shares
Gentlemen:
On behalf of the above entitled issuer, we advise you as follows:
1. This notice is filed for the fiscal year ended March 31, 1995.
2. No securities of the issuers have been registered under the Securities
Act of 1933 other than under Rule 24F-2. All securities sold by the
issuers have been sold in reliance upon Rule 24F-2.
3. During the fiscal year the issuers sold 417,064 shares (exclusive of
stock dividends not deemed to be sales) for an aggregate sale price of
$4,288,941. During the same period the issuer redeemed 137,271 shares
for an aggregate redemption price of $1,417,420. Thus, the aggregate
net sales price for the fiscal year is $2,871,522.
4. Enclosed is a cashier's check in the amount of $990.18 based upon the
net sales shown in paragraph 3 above.
5. Attached hereto is a legal opinion that all shares sold during the
fiscal year were legally issued, fully paid and non-assessable.
Dated this 22nd day of May, 1995.
CAPITAL VALUE FUND, INC.
BY
Ruth L. Prochaska, Secretary
<PAGE>
RULE 24F-2 NOTICE
SECURITIES AND EXCHANGE COMMISSION
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
RE: Rule 24F-2 Notice for Capital Value Fund, Inc.,
Equity Portfolio-Select Shares
Gentlemen:
On behalf of the above entitled issuer, we advise you as follows:
1. This notice is filed for the fiscal year ended March 31, 1995.
2. No securities of the issuers have been registered under the Securities
Act of 1933 other than under Rule 24F-2. All securities sold by the
issuers have been sold in reliance upon Rule 24F-2.
3. During the fiscal year the issuers sold 256,010 shares (exclusive of
stock dividends not deemed to be sales) for an aggregate sale price of
$2,630,529. During the same period the issuer redeemed 36,651 shares
for an aggregate redemption price of $382,736. Thus, the aggregate net
sales price for the fiscal year is $2,247,793.
4. Enclosed is a cashier's check in the amount of $775.10 based upon the
net sales shown in paragraph 3 above.
5. Attached hereto is a legal opinion that all shares sold during the
fiscal year were legally issued, fully paid and non-assessable.
Dated this 22nd day of May, 1995.
CAPITAL VALUE FUND, INC.
BY
Ruth L. Prochaska, Secretary
<PAGE>
RULE 24F-2 NOTICE
SECURITIES AND EXCHANGE COMMISSION
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
RE: Rule 24F-2 Notice for Capital Value Fund, Inc.,
Total Return Portfolio-Initial Shares
Gentlemen:
On behalf of the above entitled issuer, we advise you as follows:
1. This notice is filed for the fiscal year ended March 31, 1995.
2. No securities of the issuers have been registered under the Securities
Act of 1933 other than under Rule 24F-2. All securities sold by the
issuers have been sold in reliance upon Rule 24F-2.
3. During the fiscal year the issuers sold 185,100 shares (exclusive of
stock dividends not deemed to be sales) for an aggregate sale price of
$1,818,665. During the same period the issuer redeemed 67,692 shares
for an aggregate redemption price of $683,287. Thus, the aggregate net
sales price for the fiscal year is $1,135,378.
4. Enclosed is a cashier's check in the amount of $391.51 based upon the
net sales shown in paragraph 3 above.
5. Attached hereto is a legal opinion that all shares sold during the
fiscal year were legally issued, fully paid and non-assessable.
Dated this 22nd day of May, 1995.
CAPITAL VALUE FUND, INC.
BY
Ruth L. Prochaska, Secretary
<PAGE>
RULE 24F-2 NOTICE
SECURITIES AND EXCHANGE COMMISSION
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
RE: Rule 24F-2 Notice for Capital Value Fund, Inc.,
Total Return Portfolio-Select Shares
Gentlemen:
On behalf of the above entitled issuer, we advise you as follows:
1. This notice is filed for the fiscal year ended March 31, 1995.
2. No securities of the issuers have been registered under the Securities
Act of 1933 other than under Rule 24F-2. All securities sold by the
issuers have been sold in reliance upon Rule 24F-2.
3. During the fiscal year the issuers sold 294,364 shares (exclusive of
stock dividends not deemed to be sales) for an aggregate sale price of
$2,905,801. During the same period the issuer redeemed 58,472 shares
for an aggregate redemption price of $564,823. Thus, the aggregate net
sales price for the fiscal year is $2,340,978.
4. Enclosed is a cashier's check in the amount of $807.23 based upon the
net sales shown in paragraph 3 above.
5. Attached hereto is a legal opinion that all shares sold during the
fiscal year were legally issued, fully paid and non-assessable.
Dated this 22nd day of May, 1995.
CAPITAL VALUE FUND, INC.
BY
Ruth L. Prochaska, Secretary
<PAGE>
RULE 24F-2 NOTICE
SECURITIES AND EXCHANGE COMMISSION
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
RE: Rule 24F-2 Notice for Capital Value Fund, Inc.,
Fixed Income Portfolio-Initial Shares
Gentlemen:
On behalf of the above entitled issuer, we advise you as follows:
1. This notice is filed for the fiscal year ended March 31, 1995.
2. No securities of the issuers have been registered under the Securities
Act of 1933 other than under Rule 24F-2. All securities sold by the
issuers have been sold in reliance upon Rule 24F-2.
3. During the fiscal year the issuers sold 123,030 shares (exclusive of
stock dividends not deemed to be sales) for an aggregate sale price of
$1,165,760. During the same period the issuer redeemed 38,373 shares
for an aggregate redemption price of $367,262. Thus, the aggregate net
sales price for the fiscal year is $798,498.
4. Enclosed is a cashier's check in the amount of $275.34 based upon the
net sales shown in paragraph 3 above.
5. Attached hereto is a legal opinion that all shares sold during the
fiscal year were legally issued, fully paid and non-assessable.
Dated this 22nd day of May, 1995.
CAPITAL VALUE FUND, INC.
BY
Ruth L. Prochaska, Secretary
<PAGE>
RULE 24F-2 NOTICE
SECURITIES AND EXCHANGE COMMISSION
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
RE: Rule 24F-2 Notice for Capital Value Fund, Inc.,
Fixed Income Portfolio-Select Shares
Gentlemen:
On behalf of the above entitled issuer, we advise you as follows:
1. This notice is filed for the fiscal year ended March 31, 1995.
2. No securities of the issuers have been registered under the Securities
Act of 1933 other than under Rule 24F-2. All securities sold by the
issuers have been sold in reliance upon Rule 24F-2.
3. During the fiscal year the issuers sold 35,704 shares (exclusive of
stock dividends not deemed to be sales) for an aggregate sale price of
$338,704. During the same period the issuer redeemed 3,404 shares for
an aggregate redemption price of $32,308. Thus, the aggregate net sales
price for the fiscal year is $306,396.
4. Enclosed is a cashier's check in the amount of $105.65 based upon the
net sales shown in paragraph 3 above.
5. Attached hereto is a legal opinion that all shares sold during the
fiscal year were legally issued, fully paid and non-assessable.
Dated this 22nd day of May, 1995.
CAPITAL VALUE FUND, INC.
BY
Ruth L. Prochaska, Secretary
<PAGE>
RULE 24F-2 NOTICE
SECURITIES AND EXCHANGE COMMISSION
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
RE: Rule 24F-2 Notice for Capital Value Fund, Inc.,
Short-Term Government Portfolio-Initial Shares
Gentlemen:
On behalf of the above entitled issuer, we advise you as follows:
1. This notice is filed for the fiscal year ended March 31, 1995.
2. No securities of the issuers have been registered under the Securities
Act of 1933 other than under Rule 24F-2. All securities sold by the
issuers have been sold in reliance upon Rule 24F-2.
3. During the fiscal year the issuers sold 2,891 shares (exclusive of
stock dividends not deemed to be sales) for an aggregate sale price of
$27,962. During the same period the issuer redeemed 7,594 shares for an
aggregate redemption price of $72,366. Thus, the aggregate net sales
price for the fiscal year is $(44,404).
4. No fee is required based upon the net sales shown in paragraph 3 above.
5. Attached hereto is a legal opinion that all shares sold during the
fiscal year were legally issued, fully paid and non-assessable.
Dated this 22nd day of May, 1995.
CAPITAL VALUE FUND, INC.
BY
Ruth L. Prochaska, Secretary
<PAGE>
RULE 24F-2 NOTICE
SECURITIES AND EXCHANGE COMMISSION
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
RE: Rule 24F-2 Notice for Capital Value Fund, Inc.,
Short-Term Government Portfolio-Select Shares
Gentlemen:
On behalf of the above entitled issuer, we advise you as follows:
1. This notice is filed for the fiscal year ended March 31, 1995.
2. No securities of the issuers have been registered under the Securities
Act of 1933 other than under Rule 24F-2. All securities sold by the
issuers have been sold in reliance upon Rule 24F-2.
3. During the fiscal year the issuers sold 18,016 shares (exclusive of
stock dividends not deemed to be sales) for an aggregate sale price of
$175,604. During the same period the issuer redeemed 6,852 shares for
an aggregate redemption price of $66,826. Thus, the aggregate net sales
price for the fiscal year is $108,778.
4. Enclosed is a cashier's check in the amount of $37.51 based upon the
net sales shown in paragraph 3 above.
5. Attached hereto is a legal opinion that all shares sold during the
fiscal year were legally issued, fully paid and non-assessable.
Dated this 22nd day of May, 1995.
CAPITAL VALUE FUND, INC.
BY
Ruth L. Prochaska, Secretary
<PAGE>
RULE 24F-2 NOTICE
SECURITIES AND EXCHANGE COMMISSION
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
RE: Rule 24F-2 Notice for Capital Value Fund, Inc.,
Prime Money Market Portfolio
Gentlemen:
On behalf of the above entitled issuer, we advise you as follows:
1. This notice is filed for the fiscal year ended March 31, 1995.
2. No securities of the issuers have been registered under the Securities
Act of 1933 other than under Rule 24F-2. All securities sold by the
issuers have been sold in reliance upon Rule 24F-2.
3. During the fiscal year the issuers sold 3,758,731 shares (exclusive of
stock dividends not deemed to be sales) for an aggregate sale price of
$3,758,731. During the same period the issuer redeemed 3,543,249 shares
for an aggregate redemption price of $3,543,249. Thus, the aggregate
net sales price for the fiscal year is $215,482.
4. Enclosed is a cashier's check in the amount of $74.30 based upon the
net sales shown in paragraph 3 above.
5. Attached hereto is a legal opinion that all shares sold during the
fiscal year were legally issued, fully paid and non-assessable.
Dated this 22nd day of May, 1995.
CAPITAL VALUE FUND, INC.
BY
Ruth L. Prochaska, Secretary
<PAGE>
May 22, 1995
Capital Value Fund, Inc.
720 Liberty Building
418 Sixth Avenue
Des Moines, Iowa 50309-2410
Re:Equity Portfolio Series - Initial Shares
Gentlemen:
Capital Value Fund, Inc. (the "Fund") is a corporation organized
under the laws of the State of Maryland on October 7, 1992 having its principal
place of business in Des Moines, Iowa.
We understand that, pursuant to Rule 24f-2 under the Investment Company
Act of 1940, the Fund registered an indefinite number of shares of its capital
stock, effective May 20, 1993.
We further understand that, pursuant to the provisions of Rule 24f-2,
you are about to file with the Securities and Exchange Commission a notice
making definite registration of 417,064 shares of capital stock of the Initial
Shares Class of the Fund's Equity Fund's Portfolio Series (the "Shares") sold in
reliance upon Rule 24f-2 during the fiscal year ended March 31, 1995.
We have examined original or copies, certified or otherwise identified
to our satisfaction, of the Charter, By-Laws, and records of corporate
proceedings of the Fund, and such affidavits and advices from officers of the
Fund or from public officials, as we have deemed necessary or appropriate for
the purpose of this opinion.
We are of the opinion that all of the Shares were legally and validly
issued, and are fully paid and non-assessable. The opinion expressed in the
preceding sentence is based upon the assumption that cash consideration was
received by the Fund for each such Share in an amount not less than the per
share net asset value of the Initial Shares Class of the Fund's Equity Portfolio
Series.
We express no opinion as to compliance with the Securities Act of
1933, the Investment Company Act of 1940 or the securities laws of any state
with respect to the issuance of the Shares.
We consent to your filing this opinion with the Securities and Exchange
Commission in connection with the Rule 24f-2 Notice which you are about to file
pursuant to the Investment Company Act of 1940.
Sincerely,
Ober, Kaler, Grimes & Shriver
a professional corporation
<PAGE>
May 22, 1995
Capital Value Fund, Inc.
720 Liberty Building
418 Sixth Avenue
Des Moines, Iowa 50309-2410
Re:Equity Portfolio Series - Select Shares
Gentlemen:
Capital Value Fund, Inc. (the "Fund") is a corporation organized
under the laws of the State of Maryland on October 7, 1992, having its principal
place of business in Des Moines, Iowa.
We understand that, pursuant to Rule 24f-2 under the Investment Company
Act of 1940, the Fund registered an indefinite number of shares of its capital
stock, effective May 20, 1993.
We further understand that, pursuant to the provisions of Rule 24f-2,
you are about to file with the Securities and Exchange Commission a notice
making definite registration of 256,010 shares of capital stock of the Select
Shares Class of the Fund's Equity Portfolio Series (the "Shares") sold in
reliance upon Rule 24f-2 during the fiscal year ended March 31, 1995.
We have examined original or copies, certified or otherwise identified
to our satisfaction, of the Charter, By-Laws, and records of corporate
proceedings of the Fund, and such affidavits and advices from officers of the
Fund or from public officials, as we have deemed necessary or appropriate for
the purpose of this opinion.
We are of the opinion that all of the Shares were legally and validly
issued, and are fully paid and non-assessable. The opinion expressed in the
preceding sentence is based upon the assumption that cash consideration was
received by the Fund for each such Share in an amount not less than the per
share net asset value of the Select Shares Class of the Fund's Equity Portfolio
Series.
We express no opinion as to compliance with the Securities Act of 1933,
the Investment Company Act of 1940 or the securities laws of any state with
respect to the issuance of the Shares.
We consent to your filing this opinion with the Securities and Exchange
Commission in connection with the Rule 24f-2 Notice which you are about to file
pursuant to the Investment Company Act of 1940.
Sincerely,
Ober, Kaler, Grimes & Shriver
a professional corporation
<PAGE>
May 22, 1995
Capital Value Fund, Inc.
720 Liberty Building
418 Sixth Avenue
Des Moines, Iowa 50309-2410
Re:Total Return Portfolio Series - Initial Shares
Gentlemen:
Capital Value Fund, Inc. (the "Fund") is a corporation organized under
the laws of the State of Maryland on October 7, 1992, having its principal place
of business in Des Moines, Iowa.
We understand that, pursuant to Rule 24f-2 under the Investment Company
Act of 1940, the Fund registered an indefinite number of shares of its capital
stock, effective May 20, 1993.
We further understand that, pursuant to the provisions of Rule 24f-2,
you are about to file with the Securities and Exchange Commission a notice
making definite registration of 185,100 shares of capital stock of the Initial
Shares Class of the Fund's Total Return Portfolio Series (the "Shares") sold in
reliance upon Rule 24f-2 during the fiscal year ended March 31, 1995.
We have examined original or copies, certified or otherwise identified
to our satisfaction, of the Charter, By-Laws, and records of corporate
proceedings of the Fund, and such affidavits and advices from officers of the
Fund or from public officials, as we have deemed necessary or appropriate for
the purpose of this opinion.
We are of the opinion that all of the Shares were legally and validly
issued, and are fully paid and non-assessable. The opinion expressed in the
preceding sentence is based upon the assumption that cash consideration was
received by the Fund for each such Share in an amount not less than the per
share net asset value of the Initial Shares Class of the Fund's Total Return
Portfolio Series.
We express no opinion as to compliance with the Securities Act of 1933,
the Investment Company Act of 1940 or the securities laws of any state with
respect to the issuance of the Shares.
We consent to your filing this opinion with the Securities and Exchange
Commission in connection with the Rule 24f-2 Notice which you are about to file
pursuant to the Investment Company Act of 1940.
Sincerely,
Ober, Kaler, Grimes & Shriver
a professional corporation
<PAGE>
May 22, 1995
Capital Value Fund, Inc.
720 Liberty Building
418 Sixth Avenue
Des Moines, Iowa 50309-2410
Re:Total Return Portfolio Series - Select Shares
Gentlemen:
Capital Value Fund, Inc. (the "Fund") is a corporation organized under
the laws of the State of Maryland on October 7, 1992, having its principal place
of business in Des Moines, Iowa.
We understand that, pursuant to Rule 24f-2 under the Investment Company
Act of 1940, the Fund registered an indefinite number of shares of its capital
stock, effective May 20, 1993.
We further understand that, pursuant to the provisions of Rule 24f-2,
you are about to file with the Securities and Exchange Commission a notice
making definite registration of 294,364 shares of capital stock of the Select
Shares Class of the Fund's Total Return Portfolio Series (the "Shares") sold in
reliance upon Rule 24f-2 during the fiscal year ended March 31, 1995.
We have examined original or copies, certified or otherwise identified
to our satisfaction, of the Charter, By-Laws, and records of corporate
proceedings of the Fund, and such affidavits and advices from officers of the
Fund or from public officials, as we have deemed necessary or appropriate for
the purpose of this opinion.
We are of the opinion that all of the Shares were legally and validly
issued, and are fully paid and non-assessable. The opinion expressed in the
preceding sentence is based upon the assumption that cash consideration was
received by the Fund for each such Share in an amount not less than the per
share net asset value of the Select Shares Class of the Fund's Total Return
Portfolio Series.
We express no opinion as to compliance with the Securities Act of 1933,
the Investment Company Act of 1940 or the securities laws of any state with
respect to the issuance of the Shares.
We consent to your filing this opinion with the Securities and Exchange
Commission in connection with the Rule 24f-2 Notice which you are about to file
pursuant to the Investment Company Act of 1940.
Sincerely,
Ober, Kaler, Grimes & Shriver
a professional corporation
<PAGE>
May 22, 1995
Capital Value Fund, Inc.
720 Liberty Building
418 Sixth Avenue
Des Moines, Iowa 50309-2410
Re:Fixed Income Portfolio Series - Initial Shares
Gentlemen:
Capital Value Fund, Inc. (the "Fund") is a corporation organized under
the laws of the State of Maryland on October 7, 1992, having its principal place
of business in Des Moines, Iowa.
We understand that, pursuant to Rule 24f-2 under the Investment Company
Act of 1940, the Fund registered an indefinite number of shares of its capital
stock, effective May 20, 1993.
We further understand that, pursuant to the provisions of Rule 24f-2,
you are about to file with the Securities and Exchange Commission a notice
making definite registration of 123,030 shares of capital stock of the Initial
Shares Class of the Fund's Fixed Income Portfolio Series (the "Shares") sold in
reliance upon Rule 24f-2 during the fiscal year ended March 31, 1995.
We have examined original or copies, certified or otherwise identified
to our satisfaction, of the Charter, By-Laws, and records of corporate
proceedings of the Fund, and such affidavits and advices from officers of the
Fund or from public officials, as we have deemed necessary or appropriate for
the purpose of this opinion.
We are of the opinion that all of the Shares were legally and validly
issued, and are fully paid and non-assessable. The opinion expressed in the
preceding sentence is based upon the assumption that cash consideration was
received by the Fund for each such Share in an amount not less than the per
share net asset value of the Initial Shares Class of the Fund's Fixed Income
Portfolio Series.
We express no opinion as to compliance with the Securities Act of 1933,
the Investment Company Act of 1940 or the securities laws of any state with
respect to the issuance of the Shares.
We consent to your filing this opinion with the Securities and Exchange
Commission in connection with the Rule 24f-2 Notice which you are about to file
pursuant to the Investment Company Act of 1940.
Sincerely,
Ober, Kaler, Grimes & Shriver
a professional corporation
<PAGE>
May 22, 1995
Capital Value Fund, Inc.
720 Liberty Building
418 Sixth Avenue
Des Moines, Iowa 50309-2410
Re:Fixed Income Portfolio Series - Select Shares
Gentlemen:
Capital Value Fund, Inc. (the "Fund") is a corporation organized under
the laws of the State of Maryland on October 7, 1992, having its principal place
of business in Des Moines, Iowa.
We understand that, pursuant to Rule 24f-2 under the Investment Company
Act of 1940, the Fund registered an indefinite number of shares of its capital
stock, effective May 20, 1993.
We further understand that, pursuant to the provisions of Rule 24f-2,
you are about to file with the Securities and Exchange Commission a notice
making definite registration of 35,704 shares of capital stock of the Select
Shares Class of the Fund's Fixed Income Portfolio Series (the "Shares") sold in
reliance upon Rule 24f-2 during the fiscal year ended March 31, 1995.
We have examined original or copies, certified or otherwise identified
to our satisfaction, of the Charter, By-Laws, and records of corporate
proceedings of the Fund, and such affidavits and advices from officers of the
Fund or from public officials, as we have deemed necessary or appropriate for
the purpose of this opinion.
We are of the opinion that all of the Shares were legally and validly
issued, and are fully paid and non-assessable. The opinion expressed in the
preceding sentence is based upon the assumption that cash consideration was
received by the Fund for each such Share in an amount not less than the per
share net asset value of the Select Shares Class of the Fund's Fixed Income
Portfolio Series.
We express no opinion as to compliance with the Securities Act of 1933,
the Investment Company Act of 1940 or the securities laws of any state with
respect to the issuance of the Shares.
We consent to your filing this opinion with the Securities and Exchange
Commission in connection with the Rule 24f-2 Notice which you are about to file
pursuant to the Investment Company Act of 1940.
Sincerely,
Ober, Kaler, Grimes & Shriver
a professional corporation
<PAGE>
May 22, 1995
Capital Value Fund, Inc.
720 Liberty Building
418 Sixth Avenue
Des Moines, Iowa 50309-2410
Re:Short-Term Government Portfolio Series - Initial Shares
Gentlemen:
Capital Value Fund, Inc. (the "Fund") is a corporation organized under
the laws of the State of Maryland on October 7, 1992, having its principal place
of business in Des Moines, Iowa.
We understand that, pursuant to Rule 24f-2 under the Investment Company
Act of 1940, the Fund registered an indefinite number of shares of its capital
stock, effective May 20, 1993.
We further understand that, pursuant to the provisions of Rule 24f-2,
you are about to file with the Securities and Exchange Commission a notice
making definite registration of 2,891 shares of capital stock of the Initial
Shares Class of the Fund's Short-Term Government Portfolio Series (the "Shares")
sold in reliance upon Rule 24f-2 during the fiscal year ended March 31, 1995.
We have examined original or copies, certified or otherwise identified
to our satisfaction, of the Charter, By-Laws, and records of corporate
proceedings of the Fund, and such affidavits and advices from officers of the
Fund or from public officials, as we have deemed necessary or appropriate for
the purpose of this opinion.
We are of the opinion that all of the Shares were legally and validly
issued, and are fully paid and non-assessable. The opinion expressed in the
preceding sentence is based upon the assumption that cash consideration was
received by the Fund for each such Share in an amount not less than the per
share net asset value of the Initial Shares Class of the Fund's Short-Term
Government Portfolio Series.
We express no opinion as to compliance with the Securities Act of 1933,
the Investment Company Act of 1940 or the securities laws of any state with
respect to the issuance of the Shares.
We consent to your filing this opinion with the Securities and Exchange
Commission in connection with the Rule 24f-2 Notice which you are about to file
pursuant to the Investment Company Act of 1940.
Sincerely,
Ober, Kaler, Grimes & Shriver
a professional corporation
<PAGE>
May 22, 1995
Capital Value Fund, Inc.
720 Liberty Building
418 Sixth Avenue
Des Moines, Iowa 50309-2410
Re:Short-Term Government Portfolio Series - Select Shares
Gentlemen:
Capital Value Fund, Inc. (the "Fund") is a corporation organized under
the laws of the State of Maryland on October 7, 1992, having its principal place
of business in Des Moines, Iowa.
We understand that, pursuant to Rule 24f-2 under the Investment Company
Act of 1940, the Fund registered an indefinite number of shares of its capital
stock, effective May 20, 1993.
We further understand that, pursuant to the provisions of Rule 24f-2,
you are about to file with the Securities and Exchange Commission a notice
making definite registration of 18,016 shares of capital stock of the Select
Shares Class of the Fund's Short-Term Government Series (the "Shares") sold in
reliance upon Rule 24f-2 during the fiscal year ended March 31, 1995.
We have examined original or copies, certified or otherwise identified
to our satisfaction, of the Charter, By-Laws, and records of corporate
proceedings of the Fund, and such affidavits and advices from officers of the
Fund or from public officials, as we have deemed necessary or appropriate for
the purpose of this opinion.
We are of the opinion that all of the Shares were legally and validly
issued, and are fully paid and non-assessable. The opinion expressed in the
preceding sentence is based upon the assumption that cash consideration was
received by the Fund for each such Share in an amount not less than the per
share net asset value of the Select Shares Class of the Fund's Short-Term
Government Portfolio Series.
We express no opinion as to compliance with the Securities Act of 1933,
the Investment Company Act of 1940 or the securities laws of any state with
respect to the issuance of the Shares.
We consent to your filing this opinion with the Securities and Exchange
Commission in connection with the Rule 24f-2 Notice which you are about to file
pursuant to the Investment Company Act of 1940.
Sincerely,
Ober, Kaler, Grimes & Shriver
a professional corporation
<PAGE>
May 22, 1995
Capital Value Fund, Inc.
720 Liberty Building
418 Sixth Avenue
Des Moines, Iowa 50309-2410
Re:Prime Money Market Portfolio Series
Gentlemen:
Capital Value Fund, Inc. (the "Fund") is a corporation organized under
the laws of the State of Maryland on October 7, 1992, having its principal place
of business in Des Moines, Iowa.
We understand that, pursuant to Rule 24f-2 under the Investment Company
Act of 1940, the Fund registered an indefinite number of shares of its capital
stock, effective May 20, 1993.
We further understand that, pursuant to the provisions of Rule 24f-2,
you are about to file with the Securities and Exchange Commission a notice
making definite registration of 3,758,731 shares of capital stock of the Fund's
Prime Money Market Portfolio Series (the "Shares") sold in reliance upon Rule
24f-2 during the fiscal year ended March 31, 1995.
We have examined original or copies, certified or otherwise identified
to our satisfaction, of the Charter, By-Laws, and records of corporate
proceedings of the Fund, and such affidavits and advices from officers of the
Fund or from public officials, as we have deemed necessary or appropriate for
the purpose of this opinion.
We are of the opinion that all of the Shares were legally and validly
issued, and are fully paid and non-assessable. The opinion expressed in the
preceding sentence is based upon the assumption that cash consideration was
received by the Fund for each such Share in an amount not less than the per
share net asset value of the Fund's Prime Money Market Portfolio Series.
We express no opinion as to compliance with the Securities Act of 1933,
the Investment Company Act of 1940 or the securities laws of any state with
respect to the issuance of the Shares.
We consent to your filing this opinion with the Securities and Exchange
Commission in connection with the Rule 24f-2 Notice which you are about to file
pursuant to the Investment Company Act of 1940.
Sincerely,
Ober, Kaler, Grimes & Shriver
a professional corporation
