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RULE 24f-2 NOTICE
FOR
SHORT-TERM INVESTMENTS CO.
Reg. No. 33-66240 Dated: October 18, 1995
The fiscal year for which this Notice is being filed ended August 31,
1995.
No shares of the issuer were registered pursuant to Section 270.24e-2.
There were 65,518,825,746.65 shares sold during such fiscal year. Of
those shares sold, there were 65,518,825,746.65 shares sold during this
fiscal year in reliance upon registration pursuant to Section 270.24f-2 and
no shares were sold pursuant to definite registration under Section
270.24e-2. The aggregate sale price of all shares was $65,518,825,746.65.
There were 65,189,024,010.19 shares repurchased or redeemed during such
fiscal year. The aggregate redemption price of these shares was
$65,189,024,010.19.
Calculation of the required fee is as follows (pursuant to Section 6(b)
of the Securities Act of 1933):
$ 65,518,825,746.65 Aggregate sale price of shares sold
during fiscal year
$(65,189,024,010.19) Aggregate redemption price of shares
repurchased or redeemed during fiscal
year
$ 0 Aggregate offering price of shares sold
------------------- pursuant to definite registration
$ 329,801,736.46 DIVIDED BY 2900
-------------------
$ 113,724.74 Total fee due with this Notice
===================
No redeemed or repurchased shares have been previously applied by the
issuer pursuant to Section 270.24e-2(a) in filings made pursuant to Section
270.24e-1 of the Investment Company Act for such period.
This Rule 24f-2 Notice is accompanied by the required opinion of counsel
furnished by Ballard Spahr Andrews & Ingersoll, legal counsel to the issuer.
/s/ DANA R. SUTTON
--------------------------------------
Dana R. Sutton
Vice President and Assistant Treasurer
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139242.001(BF)
[LETTERHEAD OF BALLARD SPAHR ANDREWS & INGERSOLL]
October 20, 1995
Short-Term Investments Co.
11 Greenway Plaza, Suite 1919
Houston, TX 77046
Re: Rule 24f-2 Notice for Short-Term Investments Co.
(Securities Act File No. 33-66240)
------------------------------------------------
Gentlemen:
We have acted as counsel to Short-Term Investments Co. (the
"Fund"), a corporation organized under the laws of the State of Maryland and
registered with the Securities and Exchange Commission under the Investment
Company Act of 1940 as an open-end series management investment company.
We have been informed that a registration statement on Form N-1A,
as amended ("Registration Statement") relating to an indefinite number of
shares of common stock of the Fund (the "Shares") has been filed with the
Securities and Exchange Commission under the Securities Act of 1933
(Securities Act File No. 33-66240).
We further understand that, pursuant to the provisions of Rule
24f-2, the Fund is filing with the Securities and Exchange Commission a
notice (the "Notice") making definite the registration of such Shares sold in
reliance on Rule 24f-2 for the fiscal year ended August 31, 1995.
Specifically, we have been informed by the Fund that a total of
65,518,825,746.65 Shares (representing interests in series portfolios
existing during all or part of such fiscal year) were issued from time to
time during such fiscal year under Prospectuses which were included as part
of the Registration Statement. The Fund has requested our opinion in
connection with the filing of such Notice, for inclusion in such filing.
In connection with our giving this opinion, we have examined a copy
of the Charter of the Fund, as amended, and originals or copies, certified or
otherwise identified to our
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Short-Term Investments Co.
October 20, 1995
Page 2
satisfaction, of such other documents, records and other instruments as we
have deemed necessary or advisable for purposes of this opinion. As to
various questions of fact material to our opinion, we have relied upon
information provided by officers of the Fund.
Based on the foregoing, we are of the opinion that the
65,518,825,746.65 Shares issued by the Fund during its fiscal year ended
August 31, 1995 were, when issued for payment as described in the Fund's
Prospectuses referred to above, legally issued, fully paid and non-assessable
by the Fund.
Very truly yours,
/s/ BALLARD SPAHR ANDREWS & INGERSOLL
BALLARD SPAHR ANDREWS & INGERSOLL
