December 27, 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 Summit Funds, Inc.
T. Rowe Price Summit Cash Reserves Fund
T. Rowe Price Summit Limited-Term Bond Fund
T. Rowe Price Summit GNMA Fund
100 East Pratt Street
Baltimore, Maryland 21202
File Number 33-50319
Gentlemen:
In accordance with the provisions of Rule 24f-2, the T. Rowe Price
Summit Funds, Inc. hereby files its Rule 24f-2 Notice on behalf of its
T. Rowe Price Summit Cash Reserves Fund ("Cash Reserves Fund"), T. Rowe
Price Summit Limited-Term Bond Fund ("Limited-Term Bond Fund") and T. Rowe
Price Summit GNMA Fund ("GNMA Fund").
This "Rule 24f-2 Notice" is being filed for the Fiscal Year ending
October 31, 1994 for the Cash Reserves, Limited-Term Bond and GNMA Funds.
340,644,491, 6,653,618 and 2,285,083 shares of capital stock of the Cash
Reserves, Limited-Term Bond and GNMA Funds, respectively, were sold during
the Fiscal Year.
All 340,644,491, 6,653,618 and 2,285,083 shares of capital stock of the
Cash Reserves, Limited-Term Bond and GNMA 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 $63,189.06, 7,469.36 and 6,162.02 for the Cash
Reserves,
Limited-Term Bond and GNMA Funds, respectively, have been forwarded to
Mellon Bank, Pittsburgh, Pennsylvania. 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>
Cash Reserves Limited-Term
Fund Bond Fund
Aggregate Sale Price
for Shares Sold
During Fiscal Year
in Reliance Upon
the 24f-2 Declaration $340,644,491 $32,621,612
Reduced by the
Difference Between
(1) Aggregate Redemption
Price of Shares
Redeemed During
the Fiscal Year $157,397,510 $10,960,633
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 $183,246,981 $21,660,979
<PAGE>
GNMA Fund
Aggregate Sale Price
for Shares Sold
During Fiscal Year
in Reliance Upon
the 24f-2 Declaration $22,577,278
Reduced by the
Difference Between
(1) Aggregate Redemption
Price of Shares
Redeemed During
the Fiscal Year $ 4,707,540
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 $17,869,738
Any questions regarding the matter should be addressed
to Henry H. Hopkins, Esquire at the above address.
Very truly yours,
/s/ CARMEN F. DEYESU
December 27, 1994
T. Rowe Price Summit Funds, Inc.
100 East Pratt Street
Baltimore, Maryland 21202
Dear Sirs:
T. Rowe Price Summit Funds, Inc., a Maryland corporation (the
"Corporation"), on behalf of its designated series, T. Rowe Price Summit Cash
Reserves Fund (the "Cash Reserves Fund"), T. Rowe Price Summit Limited-Term
Fund (the "Limited-Term Fund") and T. Rowe Price Summit GNMA Fund (the "GNMA
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 in paragraph (c) of the Rule will be to make
definite in number the number of shares sold by the Cash Reserves Fund, the
Limited-Term Fund and the GNMA Fund during the fiscal year beginning November
1, 1993 and ending October 31, 1994 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 December 8, 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 of the Corporation 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.
Based upon the foregoing, it is our opinion that:
1. The Corporation has been duly organized and is legally
existing under the laws of the State of Maryland.
2. The Corporation is authorized to issue one billion
(1,000,000,000) shares of capital stock, par value ($0.0001) 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.
3. 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
