INVESTA MANAGEMENT CO.
c/o Investa Management Co., Inc.
551 Fifth Avenue
New York, New York 10176
February 23, 2000
VIA EDGAR
Securities and Exchange Commission
Division of Investment Management
450 Fifth Street, N.W.
Washington, DC 20549
Attn: Joy Kemppainen, Esq.
RE: APPLICATION FOR ORDER OF WITHDRAWAL OF REGISTRATION
STATEMENT UNDER THE SECURITIES ACT OF 1933 AND THE
INVESTMENT COMPANY ACT OF 1940 FOR INVESTA
MANAGEMENT CO., ON BEHALF OF ITS SERIES, THE
WOMAN'S FUND AND THE SUPER INDEX FUND
(COMMISSION FILE NO. 33-72506; ICA FILE NO. 811-8198)
-----------------------------------------------------
Ladies and Gentlemen:
Pursuant to Rule 477(a) promulgated under the Securities Act of 1933,
as amended, INVESTA MANAGEMENT CO., a Massachusetts business trust, on behalf of
its series, The Woman's Fund and The Super Index Fund, (the "Registrant") hereby
requests that the Securities and Exchange Commission (the "Commission") permit
the withdrawal of its Registration Statement on Form N-1A (Commission File No.
33-72506), together with all exhibits and amendments thereto (the "Registration
Statement"). The Registration Statement was originally filed with the Commission
on December 6, 1993 and amended on June 29, 1994 and May 23, 1995.
The Registrant requests that the Registration Statement be withdrawn
because the Registrant has abandoned its efforts to issue shares of common stock
for sale to the public as contemplated by the Registration Statement. No
securities have been sold under the Registration Statement and no activity in
pursuit of this offering has taken place since May 23, 1995. Accordingly, we
hereby request that an order granting the withdrawal of the Registration
Statement be issued by the Commission as soon as practicable.
Should you have any questions regarding this matter, please do not
hesitate to contact the undersigned, or Lawrence Y. Vincent, Esq. of Spitzer &
Feldman P.C. at (212) 888-6680.
Sincerely,
Investa Management Co.
By: /S/ DEREK J. HOGGETT
---------------------
Derek J. Hoggett
President
