NASDX / Shelton Funds - Shelton Nasdaq-100 Index Fund Class S - SEC Dosyaları, Yıllık Rapor, Vekil Beyanı

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

SHELTON FUNDS N-14 Exhibit 16 CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We hereby consent to the incorporation by reference in this Registration Statement on Form N-14 of our report dated May 30, 2025, relating to the financial statements and financial highlights of STF Tactical Growth & Income ETF and STF Tactical Growth ETF, each a series of Listed Funds Trust, which are included in Form N-CSR for the year ended March 31, 2025, and to the references to our firm under the headings “Information About the Reorganizations”, “Miscellaneous Information” and “Exhibit B – Financial Highlights of the Target Funds” in the Proxy Statement/Prospectus.

As filed with the Securities and Exchange Commission on June 1, 2026 Registration No. 333-294753 U.S. SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ☒ Pre-Effective Amendmen

As filed with the Securities and Exchange Commission on June 1, 2026 Registration No.

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

SHELTON FUNDS N-14/A Exhibit 14 CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We hereby consent to the incorporation by reference in this Registration Statement on Form N-14 of our report dated May 30, 2025, relating to the financial statements and financial highlights of STF Tactical Growth & Income ETF and STF Tactical Growth ETF, each a series of Listed Funds Trust, which are included in Form N-CSR for the year ended March 31, 2025, and to the references to our firm under the headings “Information About the Reorganizations”, “Miscellaneous Information” and “Exhibit B – Financial Highlights of the Target Funds” in the Preliminary Proxy Statement/Prospectus.

As filed with the Securities and Exchange Commission on May 15, 2026 Registration No. 333-294753 U.S. SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ☒ Pre-Effective Amendmen

As filed with the Securities and Exchange Commission on May 15, 2026 Registration No.

SHELTON FUNDS 1401 Lawrence Street, Suite 1550 Denver, CO 80202

SHELTON FUNDS 1401 Lawrence Street, Suite 1550 Denver, CO 80202 April 20, 2026 VIA EDGAR TRANSMISSION Ms.

As filed with the Securities and Exchange Commission on March 31, 2026 Registration No. ________ U.S. SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ☐ Pre-Effective Amendmen

As filed with the Securities and Exchange Commission on March 31, 2026 Registration No.

SHELTON FUNDS SECRETARY’S CERTIFICATE

SHELTON FUNDS N-14 Exhibit 16(b) SHELTON FUNDS SECRETARY’S CERTIFICATE I, Gregory T.

List of Funds

SHELTON FUNDS N-14 Exhibit 11 March 30, 2026 Shelton Funds 1125 17th Street, Suite 2550 Denver, CO 80202 Re: Shelton Funds 1940 Act File.

Power of Attorney

SHELTON FUNDS N-14 Exhibit 16(a) Power of Attorney Each of the undersigned Trustees and Officers of the Shelton Funds (the “Trust”), hereby appoints Shephen C.

_________, 2026

SHELTON FUNDS N-14 Exhibit 12 , 2026 STF Tactical Growth & Income Fund ETF (a series of Listed Funds Trust) 615 E.

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

SHELTON FUNDS N-14 Exhibit 14 CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We hereby consent to the incorporation by reference in this Registration Statement on Form N-14 of our report dated May 30, 2025, relating to the financial statements and financial highlights of STF Tactical Growth & Income ETF and STF Tactical Growth ETF, each a series of Listed Funds Trust, which are included in Form N-CSR for the year ended March 31, 2025, and to the references to our firm under the headings “Information About the Reorganizations”, “Miscellaneous Information” and “Exhibit B – Financial Highlights of the Target Funds” in the Preliminary Proxy Statement/Prospectus.

APP ORDR

UNITED STATES OF AMERICA BEFORE THE SECURITIES AND EXCHANGE COMMISSION INVESTMENT COMPANY ACT OF 1940 Release No.

APP NTC

SECURITIES AND EXCHANGE COMMISSION Investment Company Act Release No. 35834 Multi-Class ETF Fund Exemptive Relief under the Investment Company Act of 1940 December 17, 2025 AGENCY: Securities and Exchange Commission (“Commission” or “SEC”). ACTION: Notice. Notice of applications under section 6(c) of the Investment Company Act of 1940 (“Act”), each for an exemption from sections 2(a)(32), 5(a)(1),

APP ORDR

UNITED STATES OF AMERICA BEFORE THE SECURITIES AND EXCHANGE COMMISSION INVESTMENT COMPANY ACT OF 1940 Release No.

APP NTC

SECURITIES AND EXCHANGE COMMISSION Investment Company Act Release No. 35817; 812-15824 Shelton Funds, et al. December 4, 2025. AGENCY: Securities and Exchange Commission (“Commission” or “SEC”). ACTION: Notice. Notice of an application under section 6(c) of the Investment Company Act of 1940 (“Act”) for an exemption from section 15(a) of the Act, as well as from certain disclosure requirements in

N-MFP3

N-MFP3 0000778206 XXXXXXXX 2025-09-30 SHELTON FUNDS 0000778206 254900S73SCF59AAL583 The United States Treasury Trust 254900VYM2FC2O1XO078 S000016030 1 N N 033-00499 Shelton Capital Management 801-25205 Cohen & Company Cleveland OH Shelton Capital Management Ultimus Fund Solutions, LLC/TA 0001094887 084-05829 N N N Government N Y 33 33 26008306.

N-MFP3

N-MFP3 0000778206 XXXXXXXX 2025-08-31 SHELTON FUNDS 0000778206 254900S73SCF59AAL583 The United States Treasury Trust 254900VYM2FC2O1XO078 S000016030 1 N N 033-00499 Shelton Capital Management 801-25205 Cohen & Company Cleveland OH Shelton Capital Management Ultimus Fund Solutions, LLC/TA 0001094887 084-05829 N N N Government N Y 47 47 24766266.

SHELTON FUNDS 1125 17th Street, Ste. 2550 Denver, Colorado 80203

SHELTON FUNDS 1125 17th Street, Ste. 2550 Denver, Colorado 80203 VIA EDGAR March 5, 2025 U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549-4644 RE: Registrant: Shelton Funds (the “Trust”) File Nos.: File Nos. 033-00499 & 811-04417 Fund: Radiant U.S. Smaller Companies Fund (the “Fund”) Ladies and Gentlemen: Pursuant to Rule 477 under

S&P MIDCAP INDEX FUND

S&P MIDCAP INDEX FUND Portfolio of Investments (Unaudited) November 30, 2021 Security Description Shares Value Common Stock (108.

NASDAQ 100 INDEX FUND

NASDAQ 100 INDEX FUND Portfolio of Investments (Unaudited) 5/31/2021 Security Description Shares Value Common Stock (98.

SCHEDULE OF INVESTMENTS

SHELTON EQUITY INCOME FUND Portfolio of Investments (Unaudited) May 31, 2022 Security Description Shares Value Common Stock (88.

S&P 500 INDEX FUND

S&P 500 INDEX FUND Portfolio of Investments (Unaudited) 5/31/2021 Security Description Shares Value Common Stock (99.

NASDAQ 100 INDEX FUND

NASDAQ 100 INDEX FUND Portfolio of Investments (Unaudited) November 30, 2021 Security Description Shares Value Common Stock (100.

S&P SMALLCAP INDEX FUND

S&P SMALLCAP INDEX FUND Portfolio of Investments (Unaudited) November 30, 2021 Security Description Shares Value Common Stock (106.

SCHEDULE OF INVESTMENTS

S&P MIDCAP INDEX FUND Portfolio of Investments (Unaudited) May 31, 2022 Security Description Shares Value Common Stock (99.

SCHEDULE OF INVESTMENTS

NASDAQ 100 INDEX FUND Portfolio of Investments (Unaudited) May 31, 2022 Security Description Shares Value Common Stock (99.

S&P MIDCAP INDEX FUND

S&P MIDCAP INDEX FUND Portfolio of Investments (Unaudited) 5/31/2021 Security Description Shares Value Common Stock (99.

S&P SMALLCAP INDEX FUND

S&P SMALLCAP INDEX FUND Portfolio of Investments (Unaudited) 5/31/2021 Security Description Shares Value Common Stock (98.

SCHEDULE OF INVESTMENTS

S&P SMALLCAP INDEX FUND Portfolio of Investments (Unaudited) May 31, 2022 Security Description Shares Value Common Stock (99.

SCHEDULE OF INVESTMENTS

S&P 500 INDEX FUND Portfolio of Investments (Unaudited) May 31, 2022 Security Description Shares Value Common Stock (99.

1

P.O. Box 87 Denver, Colorado 80201 (800) 955-9988 (303) 534-5627 January 18, 2024 Via E-MAIL AND EDGAR Lauren Hamilton U.S. Securities and Exchange Commission Division of Investment Management, Disclosure Review Office 3 World Financial Center New York, NY 10281 Re: Comment/Response Letter for the Annual Report of Shelton Funds (File No. 811-04417) (the “Registrant”) dated August 31, 2022, as file

As filed with the Securities and Exchange Commission on January 5, 2024 File Nos. 33-499 and 811-4417 SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A Registration Statement Under the Securities Act of 1933 Post-Effective Amendment

As filed with the Securities and Exchange Commission on January 5, 2024 File Nos. 33-499 and 811-4417 SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A Registration Statement Under the Securities Act of 1933 Post-Effective Amendment No. 73 and Registration Statement Under the Investment Company Act of 1940 Amendment No. 74 SHELTON FUNDS (Exact Name of Registrant as Specified in i

Name of Fund

Shelton Funds POS EX EXHIBIT 99.(h5) P.O. Box 87 Denver, Colorado 80201 (800) 955-9988 (303) 534-5627 January 3, 2024 Shelton Funds 1875 Lawrence Street, Suite 300 Denver, CO 80202-1805 Re: Certain Expense Limits Gentlemen, CCM Partners, LP d/b/a Shelton Capital Management (“SCM”), as the investment adviser to the various series funds (each a “Fund”, collectively the “Funds”) of Shelton Funds, her

Green CALIFORNIA TAX FREE INCOME FUND

Green CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments 5/31/2023 SECURITY DESCRIPTION Par Value Value Municipal Bonds (91.

Green CALIFORNIA TAX FREE INCOME FUND

Green CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) November 30, 2022 SECURITY DESCRIPTION Par Value Value Municipal Bonds (92.

Green CALIFORNIA TAX FREE INCOME FUND

Green CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) November 30, 2022 SECURITY DESCRIPTION Par Value Value Municipal Bonds (92.

Green CALIFORNIA TAX FREE INCOME FUND

Green CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) November 30, 2022 SECURITY DESCRIPTION Par Value Value Municipal Bonds (92.

Green CALIFORNIA TAX FREE INCOME FUND

Green CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) November 30, 2022 SECURITY DESCRIPTION Par Value Value Municipal Bonds (92.

Green CALIFORNIA TAX FREE INCOME FUND

Green CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) November 30, 2022 SECURITY DESCRIPTION Par Value Value Municipal Bonds (92.

Green CALIFORNIA TAX FREE INCOME FUND

Green CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) November 30, 2022 SECURITY DESCRIPTION Par Value Value Municipal Bonds (92.

Green CALIFORNIA TAX FREE INCOME FUND

Green CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) November 30, 2022 SECURITY DESCRIPTION Par Value Value Municipal Bonds (92.

Green CALIFORNIA TAX FREE INCOME FUND

Green CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) November 30, 2022 SECURITY DESCRIPTION Par Value Value Municipal Bonds (92.

As filed with the Securities and Exchange Commission on January 11, 2023 File Nos. 33-499 and 811-4417 SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A Registration Statement Under the Securities Act of 1933 Post-Effective Amendmen

As filed with the Securities and Exchange Commission on January 11, 2023 File Nos.

Amendment No. 1 to the Investment Advisory Agreement dated February 14, 2013, between Shelton Funds, on behalf of the Shelton Sustainable Equity Fund (formerly known as the Shelton Green Alpha Fund)

SHELTON FUNDS POS-EX Exhibit (d)(3) Amendment No. 1 to Investment Advisory Agreement This Amendment dated effective as of October 10, 2022 (this “Amendment”) is to the Investment Advisory Agreement dated as of February 14, 2013 (the “Agreement”), by and between Shelton Funds, a Delaware statutory trust (the “Trust”), and CCM Partners, LP a California limited partnership d/b/a Shelton Capital Manag

Expense Limitation Letter dated January 6, 2023

SHELTON FUNDS POS-EX Exhibit (h)(5) P.O. Box 87 Denver, Colorado 80201 (800) 955-9988 (303) 534-5627 January 6, 2023 Shelton Funds 1875 Lawrence Street, Suite 300 Denver, CO 80202-1805 Re: Certain Expense Limits Gentlemen, CCM Partners, LP d/b/a Shelton Capital Management (“SCM”), as the investment adviser to the various series funds (each a “Fund”, collectively the “Funds”) of Shelton Funds, here

Amended and Restated Investment Advisory Agreement dated March 4, 2022, between Shelton Funds and CCM Partners

SHELTON FUNDS POS-EX Exhibit (d)(1) AMENDED AND RESTATED INVESTMENT ADVISORY AGREEMENT THIS AMENDED AND RESTATED INVESTMENT ADVISORY AGREEMENT is made this 4th day of March, 2022 (this "Agreement"), by and between Shelton Funds, a Delaware statutory trust (the "Trust"), on behalf of the series of the Trust identified herein, and CCM Partners, a limited partnership organized and existing under the laws of the State of California (the "Adviser").

1

P.O. Box 87 Denver, Colorado 80201 MAIN (800) 955-9988 FAX (303) 534-5627 October 3, 2022 Via E-MAIL AND EDGAR Valerie Lithotomos U.S. Securities and Exchange Commission Division of Investment Management, Disclosure Review Office 3 World Financial Center New York, NY 10281 Re: Comment/Response Letter for the Shelton Funds (File Nos. 33-499 and 811-4417) in respect of the Rule 485(a) amendment to t

NPORT-EX

SHELTON EQUITY INCOME FUND Portfolio of Investments (Unaudited) May 31, 2022 Security Description Shares Value Common Stock (88.

NPORT-EX

S&P 500 INDEX FUND Portfolio of Investments (Unaudited) May 31, 2022 Security Description Shares Value Common Stock (99.

NPORT-EX

GREEN CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) May 31, 2022 SECURITY DESCRIPTION Par Value Value Municipal Bonds (91.

NPORT-EX

U.S. GOVERNMENT SECURITIES FUND Portfolio of Investments (Unaudited) May 31, 2022 Security Description Par Value Value Government National Mortgage Association (2.16%) 3.500%, 11/20/2044 116,024 $ 117,179 5.000%, 03/15/2038 83,827 88,520 5.500%, 01/15/2025 9,850 10,355 5.500%, 04/15/2036 65,929 69,577 6.000%, 01/15/2026 46,257 49,822 6.000%, 06/15/2038 27,928 30,693 Total Government National Mortg

NPORT-EX

NASDAQ 100 INDEX FUND Portfolio of Investments (Unaudited) May 31, 2022 Security Description Shares Value Common Stock (99.

NPORT-EX

S&P SMALLCAP INDEX FUND Portfolio of Investments (Unaudited) May 31, 2022 Security Description Shares Value Common Stock (99.

NPORT-EX

S&P MIDCAP INDEX FUND Portfolio of Investments (Unaudited) May 31, 2022 Security Description Shares Value Common Stock (99.

NPORT-EX

SHELTON GREEN ALPHA FUND Portfolio of Investments (Unaudited) May 31, 2022 Security Description Shares Value Common Stock (96.

Shelton Funds 1875 Lawrence Street, Suite 300 Denver, CO 80202

COVER 7 filename7.htm Shelton Funds 1875 Lawrence Street, Suite 300 Denver, CO 80202 July 21, 2022 Via EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Shelton Funds, File Nos. 033-00499 and 811-4417 Ladies and Gentlemen, On behalf of Shelton Funds (the “Trust”) we hereby submit, via electronic filing, Post-Effective Amendment No. 66 to the Trust’s Registratio

2

1875 Lawrence Street, Suite 300 Denver, Colorado 80202-1805 Main (800) 955-9988 Fax (303) 534-5627 February 16, 2022 Via E-MAIL AND EDGAR Valerie Lithotomos U.

S&P SMALLCAP INDEX FUND

S&P SMALLCAP INDEX FUND Portfolio of Investments (Unaudited) November 30, 2021 Security Description Shares Value Common Stock (106.

S&P MIDCAP INDEX FUND

S&P MIDCAP INDEX FUND Portfolio of Investments (Unaudited) November 30, 2021 Security Description Shares Value Common Stock (108.

U.S. GOVERNMENT SECURITIES FUND

U.S. GOVERNMENT SECURITIES FUND Portfolio of Investments (Unaudited) November 30, 2021 Security Description Par Value Value Government National Mortgage Association (2.22%) 3.500%, 11/20/2044 $ 137,689 $ 146,630 5.000%, 03/15/2038 85,592 98,088 5.500%, 01/15/2025 14,481 16,050 5.500%, 04/15/2036 67,518 78,399 6.000%, 01/15/2026 51,783 58,695 6.000%, 06/15/2038 28,778 33,700 Total Government Nation

SHELTON EQUITY INCOME FUND

SHELTON EQUITY INCOME FUND Portfolio of Investments (Unaudited) November 30, 2021 Security Description Shares Value Common Stock (96.

SHELTON GREEN ALPHA FUND

SHELTON GREEN ALPHA FUND Portfolio of Investments (Unaudited) November 30, 2021 Security Description Shares Value Common Stock (99.

GREEN CALIFORNIA TAX FREE INCOME FUND

GREEN CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) November 30, 2021 SECURITY DESCRIPTION Par Value Rate Maturity Value Municipal Bonds (94.

S&P 500 INDEX FUND

S&P 500 INDEX FUND Portfolio of Investments (Unaudited) November 30, 2021 Security Description Shares Value Common Stock (104.

NASDAQ 100 INDEX FUND

NASDAQ 100 INDEX FUND Portfolio of Investments (Unaudited) November 30, 2021 Security Description Shares Value Common Stock (100.

SHELTON EQUITY INCOME

SHELTON EQUITY INCOME Portfolio of Investments (Unaudited) 5/31/2021 Security Description Shares Value Common Stock (94.

S&P SMALLCAP INDEX FUND

S&P SMALLCAP INDEX FUND Portfolio of Investments (Unaudited) 5/31/2021 Security Description Shares Value Common Stock (98.

NASDAQ 100 INDEX FUND

NASDAQ 100 INDEX FUND Portfolio of Investments (Unaudited) 5/31/2021 Security Description Shares Value Common Stock (98.

S&P MIDCAP INDEX FUND

S&P MIDCAP INDEX FUND Portfolio of Investments (Unaudited) 5/31/2021 Security Description Shares Value Common Stock (99.

SHELTON GREEN ALPHA FUND

SHELTON GREEN ALPHA FUND Portfolio of Investments (Unaudited) 5/31/2021 Security Description Shares Value Common Stock (98.

SHELTON EQUITY INCOME

SHELTON EQUITY INCOME Portfolio of Investments (Unaudited) 5/31/2021 Security Description Shares Value Common Stock (94.

Green CALIFORNIA TAX FREE INCOME FUND

Green CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) 5/31/2021 SECURITY DESCRIPTION Par Value Value Municipal Bonds (98.

S&P 500 INDEX FUND

S&P 500 INDEX FUND Portfolio of Investments (Unaudited) 5/31/2021 Security Description Shares Value Common Stock (99.

U.S. GOVERNMENT SECURITIES FUND

U.S. GOVERNMENT SECURITIES FUND Portfolio of Investments (Unaudited) 5/31/2021 Security Description Par Value Value Government National Mortgage Association (2.57%) 3.500% 11/20/2044 $ 174,001 $ 186,649 5.000% 03/15/2038 87,300 99,948 5.500% 01/15/2025 18,970 21,087 5.500% 04/15/2036 83,817 96,830 6.000% 01/15/2026 60,353 68,640 6.000% 06/15/2038 33,284 39,651 Total Government National Mortgage As

S&P MIDCAP INDEX FUND

S&P MIDCAP INDEX FUND Portfolio of Investments (Unaudited) 11/30/2020 Security Description Maturity Date Shares Value (Note 1) Common Stock (107.

U.S. GOVERNMENT SECURITIES FUND

U.S. GOVERNMENT SECURITIES FUND Portfolio of Investments (Unaudited) 11/30/2020 Security Description Par Value Value (Note 1) Government National Mortgage Association (2.76%) 5.50% 01/15/2025 23,483 25,956 6.00% 01/15/2026 69,050 78,388 5.50% 04/15/2036 108,623 127,771 5.00% 03/15/2038 88,962 99,642 6.00% 06/15/2038 37,232 43,911 3.50% 11/20/2044 226,964 244,386 Total Government National Mortgage

S&P 500 INDEX FUND

S&P 500 INDEX FUND Portfolio of Investments (Unaudited) 11/30/2020 Security Description Maturity Date Shares Value (Note 1) Common Stock (106.

NASDAQ 100 INDEX FUND

NASDAQ 100 INDEX FUND Portfolio of Investments (Unaudited) 11/30/2020 Security Description Maturity Date Shares Value (Note 1) Common Stock (100.

Green CALIFORNIA TAX FREE INCOME FUND

Green CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) 11/30/2020 SECURITY DESCRIPTION Par Value Rate Maturity Value (Note 1) Municipal Bonds (94.

S&P SMALLCAP INDEX FUND

S&P SMALLCAP INDEX FUND Portfolio of Investments (Unaudited) 11/30/2020 Security Description Shares Value (Note 1) Common Stock (103.

SHELTON CORE VALUE FUND

SHELTON CORE VALUE FUND Portfolio of Investments (Unaudited) 11/30/2020 Security Description Maturity Date Shares Value (Note 1) Common Stock (106.

SHELTON GREEN ALPHA FUND

SHELTON GREEN ALPHA FUND Portfolio of Investments (Unaudited) 11/30/2020 Security Description Shares Value (Note 1) Common Stock (96.

SHELTON GREEN ALPHA FUND

SHELTON GREEN ALPHA FUND Portfolio of Investments (Unaudited) 5/31/2020 Security Description Shares Value Common Stock (97.

U.S. GOVERNMENT SECURITIES FUND

U.S. GOVERNMENT SECURITIES FUND Portfolio of Investments (Unaudited) 5/31/2020 Security Description Par Value Value Government National Mortgage Association (3.16%) 3.5% 11/20/2044 290,203 312,399 0.055% 01/15/2025 27,122 29,758 5.50% 04/15/2036 111,137 129,822 6.00% 01/15/2026 77,506 87,256 5.00% 03/15/2038 129,884 149,440 6.00% 06/15/2038 50,808 58,761 Total Government National Mortgage Associat

At May 31, 2020, unrealized appreciation/(depreciation) of securities for federal income tax purposes is as follows:

S&P 500 INDEX FUND Portfolio of Investments (Unaudited) 5/31/2020 Security Description Shares Value Common Stock (99.

SHELTON CORE VALUE FUND

SHELTON CORE VALUE FUND Portfolio of Investments (Unaudited) 5/31/2020 Security Description Shares Value Common Stock (84.

NASDAQ 100 INDEX FUND

NASDAQ 100 INDEX FUND Portfolio of Investments (Unaudited) 5/31/2020 Security Description Shares Value Common Stock (98.

S&P SMALLCAP INDEX FUND

S&P SMALLCAP INDEX FUND Portfolio of Investments (Unaudited) 5/31/2020 Security Description Shares Value Common Stock (99.

At May 31, 2020, unrealized appreciation/(depreciation) of securities for federal income tax purposes is as follows:

S&P MIDCAP INDEX FUND Portfolio of Investments (Unaudited) 5/31/2020 Security Description Shares Value Common Stock (99.

At May 31, 2020, unrealized appreciation/(depreciation) of securities for federal income tax purposes is as follows:

Green CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) 5/31/2020 SECURITY DESCRIPTION Par Value Value Municipal Bonds (98.

At November 30, 2019, unrealized appreciation/(depreciation) of securities for federal income tax purposes is as follows:

U.S. GOVERNMENT SECURITIES FUND Portfolio of Investments (Unaudited) 11/30/2019 Value Security Description Par Value Rate Maturity (Note 1) Government National Mortgage Association (4.50%) 330,021 3.500 11/20/2044 345,359 30,548 5.500 01/15/2025 32,790 125,866 5.500 04/15/2036 141,479 4,575 5.000 07/15/2020 4,598 85,682 6.000 01/15/2026 95,136 147,928 5.000 03/15/2038 164,800 63,131 6.000 06/15/20

At November 30, 2019, unrealized appreciation/(depreciation) of securities for federal income tax purposes is as follows:

S&P 500 INDEX FUND Portfolio of Investments (Unaudited) 11/30/2019 Value Security Description Maturity Date Shares (Note 1) Common Stock (106.

At November 30, 2019, unrealized appreciation/(depreciation) of securities for federal income tax purposes is as follows:

NASDAQ 100 INDEX FUND Portfolio of Investments (Unaudited) 11/30/2019 Value Security Description Maturity Date Shares (Note 1) Common Stock (106.

At November 30, 2019, unrealized appreciation/(depreciation) of securities for federal income tax purposes is as follows:

SHORT-TERM U.S. GOVERNMENT BOND FUND Portfolio of Investments (Unaudited) 11/30/2019 Value Security Description Par Value Rate Maturity (Note 1) Government National Mortgage Association (1.42%) 30,170 4.375 06/20/2034 30,773 50,028 4.125 11/20/2034 52,072 Total Government National Mortgage Association (Cost $80,535) 82,845 United States Treasury Notes (97.97%) 1,200,000 2.125 01/31/2021 1,206,094

At November 30, 2019, unrealized appreciation/(depreciation) of securities for federal income tax purposes is as follows:

SHELTON GREEN ALPHA FUND Portfolio of Investments (Unaudited) 11/30/2019 Value Security Description Shares (Note 1) Common Stock (97.

At November 30, 2019, unrealized appreciation/(depreciation) of securities for federal income tax purposes is as follows:

SHELTON CORE VALUE FUND Portfolio of Investments (Unaudited) 11/30/2019 Value Security Description Maturity Date Shares (Note 1) Common Stock (98.

At November 30, 2019, unrealized appreciation/(depreciation) of securities for federal income tax purposes is as follows:

Green CALIFORNIA TAX FREE INCOME FUND Portfolio of Investments (Unaudited) 11/30/2019 Value SECURITY DESCRIPTION Par Value Rate Maturity (Note 1) Municipal Bonds (95.

At November 30, 2019, unrealized appreciation/(depreciation) of securities for federal income tax purposes is as follows:

S&P SMALLCAP INDEX FUND Portfolio of Investments (Unaudited) 11/30/2019 Value Security Description Shares (Note 1) Common Stock (105.

At November 30, 2019, unrealized appreciation/(depreciation) of securities for federal income tax purposes is as follows:

S&P MIDCAP INDEX FUND Portfolio of Investments (Unaudited) 11/30/2019 Value Security Description Maturity Date Shares (Note 1) Common Stock (106.

P.O. Box 87

P.O. Box 87 Denver, Colorado 80201 MAIN (800) 955-9988 FAX (303) 534-5627 December 23, 2019 Via E-MAIL and EDGAR Lauren Hamilton Securities and Exchange Commission 200 Vesey Street #400 New York, NY 10281 Re: Annual Report Dated August 31, 2019 of Shelton Funds (File Nos. 33-499, 811-4417) Dear Ms. Hamilton: This letter responds to comments provided by the staff of the Division of Investment Manag

Shelton Funds NPORT-EX - -

NPORT-EX 1 fp0043716nportex.htm S&P 500 INDEX FUND Portfolio of Investments (Unaudited) 05/31/2019 Value Security Description Maturity Date Shares (Note 1) Common Stock (99.52%) Basic Materials (1.91%) Air Products & Chemicals Inc 1,615 328,798 Albemarle Corp 868 54,944 Celanese Corp 371 35,219 CF Industries Holdings Inc 1,795 72,231 Dow Inc 5,828 272,517 DuPont de Nemours Inc* 17,485 533,642 East

Shelton Funds N-Q (Quarterly Schedule of Portfolio Holdings)

As filed with the Securities and Exchange Commission on January UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

Shelton Funds N-Q (Quarterly Schedule of Portfolio Holdings)

N-Q 1 fp0034533nq.htm As filed with the Securities and Exchange Commission on July 27, 2018 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file numbers: 033-00499 and 811-04417 Shelton Funds (Exact name of registrant as specified in charter) 1050 17th St. Su

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

Shelton Funds DEFA14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A (Rule 14a-101) INFORMATION RE QUIRED IN PROXY STATEMENT SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 Filed by the Registrant [X] Filed by a Party other than the Registrant [ ] Check the appropriate box: [ ] Preliminary Proxy Statement [ ] Confidential, f

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

As filed with the Securities and Exchange Commission on January 29, 2018 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment

N-Q 1 fp0030512nq.htm As filed with the Securities and Exchange Commission on January 29, 2018 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file numbers: 033-00499 and 811-04417 Shelton Funds (Exact name of registrant as specified in charter) 1050 17th St.

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

EX-99.77B ACCT LTTR 2 fp0028860ex9977b.htm REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Shareholders and Board of Trustees Shelton Funds Denver, Colorado In planning and performing our audits of the financial statements of California Tax-Free Income Fund, U.S. Government Securities Fund, Short-Term U.S. Government Bond Fund, The United States Treasury Trust, S&P 500 Index Fund, S

As filed with the Securities and Exchange Commission on July 27, 2017

As filed with the Securities and Exchange Commission on July 27, 2017 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

CERTIFICATION

EX-99.CERT 2 fp0023589ex99cert.htm CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with

Shelton Funds

N-Q 1 fp0023589nq.htm As filed with the Securities and Exchange Commission on January 30, 2017 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file numbers: 033-00499 and 811-04417 Shelton Funds (Exact name of registrant as specified in charter) 1050 17th St.

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Shareholders and Board of Trustees Shelton Funds Denver, Colorado In planning and performing our audits of the financial statements of California Tax-Free Income Fund, U.

Shelton Funds

As filed with the Securities and Exchange Commission on July 13, 2016 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

Shelton Funds

As filed with the Securities and Exchange Commission on January 25, 2016 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

Shelton Funds

As filed with the Securities and Exchange Commission on July 7, 2015 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

Shelton Funds

N-Q 1 fp0012853nq.htm As filed with the Securities and Exchange Commission on January 21, 2015 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file numbers: 033-00499 and 811-04417 Shelton Funds (Exact name of registrant as specified in charter) 1050 17th St.

Shelton Funds CORRESP - -

CORRESP 1 filename1.htm CORRESPONDENCE FILING December 22, 2014 Mr. Jeff Long SEC Financial Reporting Re: N-CSR SOX Review Shelton Funds for 8/31/2014 Shelton Greater China Fund 12/31/2013 The following responses are provided in follow-up to the 3-year SOX review conducted on the referenced Funds. 1. California Tax Free Money Market Fund and the California Insured Intermediate Fund have been deact

TAIT, WELLER & BAKER LLP Certified Public Accounting Firm REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

TAIT, WELLER & BAKER LLP Certified Public Accounting Firm REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Shareholders and Board of Trustees Shelton Funds San Francisco, California In planning and performing our audits of the financial statements of California Tax-Free Income Fund, U.

CFNTX / Green California Tax-Free Income Fund N-Q - Quarterly Schedule of Portfolio Holdings -

As filed with the Securities and Exchange Commission on July 23, 2014 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

Quarterly Schedule of Portfolio Holdings -

N-Q 1 fp0008942nq.htm As filed with the Securities and Exchange Commission on January 22, 2014 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file numbers: 033-00499 and 811-04417 Shelton Funds (Exact name of registrant as specified in charter) 44 Montgomery

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

Quarterly Schedule of Portfolio Holdings -

As filed with the Securities and Exchange Commission on July 18, 2013 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

Quarterly Schedule of Portfolio Holdings -

As filed with the Securities and Exchange Commission on January 18, 2013 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

Quarterly Schedule of Portfolio Holdings -

As filed with the Securities and Exchange Commission on July 30, 2012 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

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44 Montgomery Street, Suite 2100 San Francisco, California 94104-4708 MAIN (800) 955-9988 FAX (415) 421-2019 January 19, 2012 Ms.

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of Shelton Funds; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

Quarterly Schedule of Portfolio Holdings -

As filed with the Securities and Exchange Commission on January 13, 2012 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period

As filed with the Securities and Exchange Commission on July 7, 2011 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Comp

N-Q 1 fp0003120nq.htm As filed with the Securities and Exchange Commission on July 7, 2011 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file numbers: 033-00499 and 811-04417 California Investment Trust (Exact name of registrant as specified in charter) 44

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period

As filed with the Securities and Exchange Commission on January 14, 2011 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment

As filed with the Securities and Exchange Commission on January 14, 2011 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

EX-99.77.B 2 fp0002166ex9977b.htm REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Shareholders and Board of Trustees California Investment Trust San Francisco, California In planning and performing our audits of the financial statements of California Tax-Free Money Market Fund, California Insured Intermediate Fund, California Tax-Free Income Fund, U.S. Government Securities Fund, The Unite

As filed with the Securities and Exchange Commission on July 27, 2010 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Com

As filed with the Securities and Exchange Commission on July 27, 2010 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period

April 26, 2010

EX-99.13.6 2 fp0001606ex9913-6.htm Exhibit 13.6 April 26, 2010 California Investment Trust on behalf of its series, Equity Income Fund U.S. Government Securities Fund The United States Treasury Trust 44 Montgomery Street Suite 2100 San Francisco, California 94104 SM&R Investments, Inc. on behalf of its series, SM&R Growth Fund SM&R Equity Income Fund SM&R Balanced Fund SM&R Government Bond Fund SM

April 26, 2010

Exhibit 13.8 April 26, 2010 California Investment Trust on behalf of its series, Equity Income Fund U.S. Government Securities Fund The United States Treasury Trust 44 Montgomery Street Suite 2100 San Francisco, California 94104 Re: Certain Expense Limits Effective Until April 30, 2011 Ladies and Gentlemen: CCM Partners, A California Limited Partnership (?Caltrust Fund Adviser?), the investment ad

Consent of Independent Registered Public Accounting Firm

Exhibit 14.1 Consent of Independent Registered Public Accounting Firm We consent to the incorporation by reference in this Registration Statement of SM&R Growth Fund, SM&R Equity Income Fund, SM&R Balanced Fund, SM&R Government Bond Fund and SM&R Money Market Fund (the Funds) of our report dated October 16, 2009, on our audit of the financial statements and financial highlights of the Funds as of

April 26, 2010

EX-99.13.7 3 fp0001606ex9913-7.htm Exhibit 13.7 April 26, 2010 SM&R Investments, Inc. on behalf of its series, SM&R Growth Fund SM&R Equity Income Fund SM&R Balanced Fund SM&R Government Bond Fund SM&R Money Market Fund 2450 South Shore Boulevard Suite 400 League City, Texas 77573 Re: Certain Expense Limits Effective Until April 30, 2011 Ladies and Gentlemen: Securities Management and Research, In

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CALIFORNIA INVESTMENT TRUST 44 Montgomery Street Suite 2100 San Francisco, California 94104 April 29, 2010 Richard Pfordte, Branch Chief U.

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CALIFORNIA INVESTMENT TRUST 44 Montgomery Street Suite 2100 San Francisco, California 94104 April 29, 2010 Mr.

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

Exhibit 14.2 CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the references to our firm in the Registration Statement on Form N-14 of California Investment Trust and to the use of our report dated October 28, 2009 on the financial statements and financial highlights of California Tax-Free Income Fund, California Insured Intermediate Fund, California Tax-Free Money Market Fun

File No. 333-165716 As filed with the SEC on April 29, 2010 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. 3 Post-Effective Amendment No. ___

N-14/A 1 fp0001606n14a.htm File No. 333-165716 As filed with the SEC on April 29, 2010 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. 3 Post-Effective Amendment No. (Check appropriate box or boxes) CALIFORNIA INVESTMENT TRUST (Exact Name of Registrant as Specified in Charter) 415-398-2727 (A

April 26, 2009

EX-99.13.7 4 fp0001580ex9913-7.htm Exhibit 13.7 April 26, 2009 SM&R Investments, Inc. on behalf of its series, SM&R Growth Fund SM&R Equity Income Fund SM&R Balanced Fund SM&R Government Bond Fund SM&R Money Market Fund 2450 South Shore Boulevard Suite 400 League City, Texas 77573 Re: Certain Expense Limits Effective Until April 30, 2011 Ladies and Gentlemen: Securities Management and Research, In

April 26, 2009

Exhibit 13.6 April 26, 2009 California Investment Trust on behalf of its series, Equity Income Fund U.S. Government Securities Fund The United States Treasury Trust 44 Montgomery Street Suite 2100 San Francisco, California 94104 SM&R Investments, Inc. on behalf of its series, SM&R Growth Fund SM&R Equity Income Fund SM&R Balanced Fund SM&R Government Bond Fund SM&R Money Market Fund 2450 South Sho

April 26, 2009

EX-99.13.8 5 fp0001580ex9913-8.htm Exhibit 13.8 April 26, 2009 California Investment Trust on behalf of its series, Equity Income Fund U.S. Government Securities Fund The United States Treasury Trust 44 Montgomery Street Suite 2100 San Francisco, California 94104 Re: Certain Expense Limits Effective Until April 30, 2011 Ladies and Gentlemen: CCM Partners, A California Limited Partnership (“Caltrus

File No. 333-165716 As filed with the SEC on April 28, 2010 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. 2 Post-Effective Amendment No. ___

File No. 333-165716 As filed with the SEC on April 28, 2010 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. 2 Post-Effective Amendment No. (Check appropriate box or boxes) CALIFORNIA INVESTMENT TRUST (Exact Name of Registrant as Specified in Charter) 415-398-2727 (Area Code and Telephone Numb

Reed Smith LLP

EX-99.11 2 fp0001580ex99-11.htm Exhibit 11 Reed Smith LLP Reed Smith Center 285 Fifth Avenue Suite 1200 Pittsburgh, PA 15222 412.288.3131 Fax 412.288.3063 April 21, 2010 The Trustees of California Investment Trust 44 Montgomery Street Suite 2100 San Francisco, California 94104 Ladies and Gentlemen: Equity Income Fund, U.S. Government Securities Fund and The United States Treasury Trust (the “Funds

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CORRESP 1 filename1.htm CALIFORNIA INVESTMENT TRUST 44 Montgomery Street Suite 2100 San Francisco, California 94104 April 28, 2010 Mr. Richard Pfordte, Branch Chief U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, DC 20549-4720 RE: CALIFORNIA INVESTMENT TRUST (“Registrant”) EQUITY INCOME FUND U.S. GOVERNMENT SECURITIES FUND THE UNITED STATES

DRAFT ___________________, 2010

EX-99.12.5 7 fp0001574ex9912-5.htm Reed Smith LLP Reed Smith Centre 225 Fifth Avenue Pittsburgh, PA 15222-2716 +1 412 288 3131 Fax +1 412 288 3063 reedsmith.com Leo N. Hitt Direct Phone: +1 412 288 3298 Email: [email protected] Exhibit 12.5 DRAFT , 2010 The United States Treasury Trust, a portfolio of California Investment Trust 44 Montgomery Street Suite 2100 San Francisco, California 94104 SM&

DRAFT ___________________, 2010

Reed Smith LLP Reed Smith Centre 225 Fifth Avenue Pittsburgh, PA 15222-2716 +1 412 288 3131 Fax +1 412 288 3063 reedsmith.

Reed Smith LLP

Exhibit 11 Reed Smith LLP Reed Smith Center 285 Fifth Avenue Suite 1200 Pittsburgh, PA 15222 412.

DRAFT ___________________, 2010

EX-99.12.1 3 fp0001574ex9912-1.htm Reed Smith LLP Reed Smith Centre 225 Fifth Avenue Pittsburgh, PA 15222-2716 +1 412 288 3131 Fax +1 412 288 3063 reedsmith.com Leo N. Hitt Direct Phone: +1 412 288 3298 Email: [email protected] Exhibit 12.1 DRAFT , 2010 Equity Income Fund, a portfolio of California Investment Trust 44 Montgomery Street Suite 2100 San Francisco, California 94104 SM&R Growth Fund,

File No. 333-165716 As filed with the SEC on April 22, 2010 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. 1 Post-Effective Amendment No. ___

N-14/A 1 fp0001574n14a.htm File No. 333-165716 As filed with the SEC on April 22, 2010 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. 1 Post-Effective Amendment No. (Check appropriate box or boxes) CALIFORNIA INVESTMENT TRUST (Exact Name of Registrant as Specified in Charter) 415-398-2727 (A

DRAFT ___________________, 2010

EX-99.12.3 5 fp0001574ex9912-3.htm Reed Smith LLP Reed Smith Centre 225 Fifth Avenue Pittsburgh, PA 15222-2716 +1 412 288 3131 Fax +1 412 288 3063 reedsmith.com Leo N. Hitt Direct Phone: +1 412 288 3298 Email: [email protected] Exhibit 12.3 DRAFT , 2010 Equity Income Fund, a portfolio of California Investment Trust 44 Montgomery Street Suite 2100 San Francisco, California 94104 SM&R Balanced Fun

DRAFT ___________________, 2010

EX-99.12.4 6 fp0001574ex9912-4.htm Reed Smith LLP Reed Smith Centre 225 Fifth Avenue Pittsburgh, PA 15222-2716 +1 412 288 3131 Fax +1 412 288 3063 reedsmith.com Leo N. Hitt Direct Phone: +1 412 288 3298 Email: [email protected] Exhibit 12.4 DRAFT , 2010 U.S. Government Securities Fund, a portfolio of California Investment Trust 44 Montgomery Street Suite 2100 San Francisco, California 94104 SM&R

You may also vote your shares by touchtone phone by calling 1-800-__-___ or through the Internet at www._______.com

Exhibit 17.2 KNOW ALL PERSONS BY THESE PRESENTS that the undersigned Shareholder(s) of the SM&R Growth Fund, a series of SM&R Investments, Inc. (the “Registrant”), hereby appoint(s) Teresa E. Axelson and Michele S. Lord or any one of them, as proxies to act at the Special Meeting of Shareholders (the "Special Meeting") to be held on [June 11], 2010, at 2450 South Shore Boulevard, Suite 400, League

You may also vote your shares by touchtone phone by calling 1-800-__-___ or through the Internet at www._______.com

Exhibit 17.6 KNOW ALL PERSONS BY THESE PRESENTS that the undersigned Shareholder(s) of the SM&R Money Market Fund, a series of SM&R Investments, Inc. (the “Registrant”), hereby appoint(s) Teresa E. Axelson and Michele S. Lord or any one of them, as proxies to act at the Special Meeting of Shareholders (the "Special Meeting") to be held on [June 11], 2010, at 2450 South Shore Boulevard, Suite 400,

You may also vote your shares by touchtone phone by calling 1-800-__-___ or through the Internet at www._______.com

Exhibit 17.5 KNOW ALL PERSONS BY THESE PRESENTS that the undersigned Shareholder(s) of the SM&R Government Bond Fund, a series of SM&R Investments, Inc. (the “Registrant”), hereby appoint(s) Teresa E. Axelson and Michele S. Lord or any one of them, as proxies to act at the Special Meeting of Shareholders (the "Special Meeting") to be held on [June 11], 2010, at 2450 South Shore Boulevard, Suite 40

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CALIFORNIA INVESTMENT TRUST 44 Montgomery Street Suite 2100 San Francisco, California 94104 March 25, 2010 EDGAR Operations Branch U.

AGREEMENT AND PLAN OF REORGANIZATION (SM&R Equity Income Fund)

Exhibit 4(2) AGREEMENT AND PLAN OF REORGANIZATION (SM&R Equity Income Fund) THIS AGREEMENT AND PLAN OF REORGANIZATION (the “Agreement”) is made as of this day of , 2010, by and between California Investment Trust, a Delaware statutory trust, with its principal place of business at 44 Montgomery Street, Suite 2100, San Francisco, California 94104 (the “Caltrust Registrant”), on behalf of its series, the Equity Income Fund (the “Surviving Fund”), and SM&R Investments, Inc.

1. For shareholders of SM&R Equity Income Fund, to approve an Agreement and Plan of Reorganization pursuant to which Equity Income Fund, a series of California Investment Trust, would acquire all of the assets of SM&R Equity Income Fund in exchange f

Exhibit 17.3 KNOW ALL PERSONS BY THESE PRESENTS that the undersigned Shareholder(s) of the SM&R Equity Income Fund, a series of SM&R Investments, Inc. (the “Registrant”), hereby appoint(s) Teresa E. Axelson and Michele S. Lord or any one of them, as proxies to act at the Special Meeting of Shareholders (the "Special Meeting") to be held on [June 11], 2010, at 2450 South Shore Boulevard, Suite 400,

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File No. 333- As filed with the SEC on March 25, 2010 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 Pre-Effective Amendment No. Post-Effective Amendment No. (Check appropriate box or boxes) CALIFORNIA INVESTMENT TRUST (Exact Name of Registrant as Specified in Charter) 415-398-2727 (Area Code and Telephone Number) 44 M

You may also vote your shares by touchtone phone by calling 1-800-__-___ or through the Internet at www._______.com

Exhibit 17.4 KNOW ALL PERSONS BY THESE PRESENTS that the undersigned Shareholder(s) of the SM&R Balanced Fund, a series of SM&R Investments, Inc. (the “Registrant”), hereby appoint(s) Teresa E. Axelson and Michele S. Lord or any one of them, as proxies to act at the Special Meeting of Shareholders (the "Special Meeting") to be held on [June 11], 2010, at 2450 South Shore Boulevard, Suite 400, Leag

SECRETARY'S CERTIFICATE CALIFORNIA INVESTMENT TRUST

Exhibit 16.1 SECRETARY'S CERTIFICATE OF CALIFORNIA INVESTMENT TRUST The undersigned, Stephen C. Rogers, Secretary of California Investment Trust (the “Trust”), hereby certifies that the following resolution was duly adopted by the Board of Trustees of the Trust on March 5, 2010, substantially and materially as follows and that said resolution has not been amended or rescinded: RESOLVED, that the B

AGREEMENT AND PLAN OF REORGANIZATION (SM&R Money Market Fund)

Exhibit 4(5) AGREEMENT AND PLAN OF REORGANIZATION (SM&R Money Market Fund) THIS AGREEMENT AND PLAN OF REORGANIZATION (the “Agreement”) is made as of this day of , 2010, by and between California Investment Trust, a Delaware statutory trust, with its principal place of business at 44 Montgomery Street, Suite 2100, San Francisco, California 94104 (the “Caltrust Registrant”), on behalf of its series, The United States Treasury Trust (the “Surviving Fund”), and SM&R Investments, Inc.

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the references to our firm in the Registration Statement on Form N-14 of California Investment Trust and to the use of our report dated October 28, 2009 on the financial statements and financial highlights of California Tax-Free Income Fund, California Insured Intermediate Fund, California Tax-Free Money Market Fund, U.

Consent of Independent Registered Public Accounting Firm

Exhibit 14.1 Consent of Independent Registered Public Accounting Firm We consent to the incorporation by reference in this Registration Statement of SM&R Growth Fund, SM&R Equity Income Fund, SM&R Balanced Fund, SM&R Government Bond Fund and SM&R Money Market Fund (the Funds) of our report dated October 16, 2009, on our audit of the financial statements and financial highlights of the Funds as of

AGREEMENT AND PLAN OF REORGANIZATION (SM&R Growth Fund)

Exhibit 4 (1) AGREEMENT AND PLAN OF REORGANIZATION (SM&R Growth Fund) THIS AGREEMENT AND PLAN OF REORGANIZATION (the “Agreement”) is made as of this day of , 2010, by and between California Investment Trust, a Delaware statutory trust, with its principal place of business at 44 Montgomery Street, Suite 2100, San Francisco, California 94104 (the “Caltrust Registrant”), on behalf of its series, the Equity Income Fund (the “Surviving Fund”), and SM&R Investments, Inc.

Reed Smith LLP

Exhibit 11 Reed Smith LLP Federated Investors Tower 12th Floor 1001 Liberty Avenue Pittsburgh, PA 15222-3779 412.

AGREEMENT AND PLAN OF REORGANIZATION (SM&R Fixed Income Fund)

Exhibit 4(4) AGREEMENT AND PLAN OF REORGANIZATION (SM&R Fixed Income Fund) THIS AGREEMENT AND PLAN OF REORGANIZATION (the “Agreement”) is made as of this day of , 2010, by and between California Investment Trust, a Delaware statutory trust, with its principal place of business at 44 Montgomery Street, Suite 2100, San Francisco, California 94104 (the “Caltrust Registrant”), on behalf of its series, the U.

AGREEMENT AND PLAN OF REORGANIZATION (SM&R Balanced Fund)

Exhibit 4(3) AGREEMENT AND PLAN OF REORGANIZATION (SM&R Balanced Fund) THIS AGREEMENT AND PLAN OF REORGANIZATION (the “Agreement”) is made as of this day of , 2010, by and between California Investment Trust, a Delaware statutory trust, with its principal place of business at 44 Montgomery Street, Suite 2100, San Francisco, California 94104 (the “Caltrust Registrant”), on behalf of its series, the Equity Income Fund (the “Surviving Fund”), and SM&R Investments, Inc.

POWER OF ATTORNEY

Exhibit 16.2 POWER OF ATTORNEY Each person whose signature appears below hereby constitutes and appoints Stephen C. Rogers, their true and lawful attorney-in-fact and agent, with full power of substitution and resubstitution for them and in their names, place and stead, in any and all capacities, to sign the Registration Statement on Form N-14 relating to the proposed reorganizations of (a) SM&R G

As filed with the Securities and Exchange Commission on January 20, 2010 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment

As filed with the Securities and Exchange Commission on January 20, 2010 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period

As filed with the Securities and Exchange Commission on July 27, 2009 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Com

As filed with the Securities and Exchange Commission on July 27, 2009 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

CERTIFICATION

CERTIFICATION I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period

As filed with the Securities and Exchange Commission on January 29, 2009 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment

As filed with the Securities and Exchange Commission on January 29, 2009 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

EX-99.CERT

I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

N-Q

As filed with the Securities and Exchange Commission on July 29, 2008 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

EX-99.CERT

I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

N-Q

As filed with the Securities and Exchange Commission on January 29, 2008 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

N-Q

As filed with the Securities and Exchange Commission on January 29, 2007 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

EX-99.CERT

I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

EX-99.77Q1(A)

CERTIFICATE OF TRUST of California Investment Trust This Certificate of Trust has been duly executed and is being filed in order to form a statutory trust pursuant to the Delaware Statutory Trust Act (12 Del.

EX-99.77M(A)

California Investment Trust II was the name of the other registered investment company involved in the merger with the registrant.

EX-99.77Q1(G)

AGREEMENT AND PLAN OF REORGANIZATION AMONG CALIFORNIA INVESTMENT TRUST, A MASSACHUSETTS BUSINESS TRUST, CALIFORNIA INVESTMENT TRUST II, A MASSACHUSETTS BUSINESS TRUST, AND CALIFORNIA INVESTMENT TRUST, A A DELAWARE STATUTORY TRUST This Agreement and Plan of Reorganization (this "Agreement") is made as of this 22nd day of December, 2006 by and among California Investment Trust ("CIT") and California Investment Trust II ("CIT II"), each a Massachusetts business trust (each a "MA-Trust" and collectively, the "MA-Trusts"), and California Investment Trust, a Delaware statutory trust (the "DE-Trust") (the MA-Trusts and the DE-Trust are hereinafter collectively referred to as the "parties").

EX-99.77M(B)

At a meeting held on February 14, 2006, all members of the Board of Trustees approved an Agreement and Plan of Reorganization that provided for the reorganization of California Investment Trust, a Massachusetts business trust, and California Investment Trust II, a Massachusetts business trust, into California Investment Trust, a Delaware Statutory Trust.

N-Q

As filed with the Securities and Exchange Commission on January 29, 2007 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

EX-99.CERT

I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

EX-99.CERT

EX-99.CERT 2 v047820cert.txt I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respec

N-Q

N-Q 1 v047820n-q.txt As filed with the Securities and Exchange Commission on July 25, 2006 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file numbers:033-00499 and 811-04417 California Investment Trust - (Exact name of registrant as specified in charter) 44

EX-99.77Q1

CERTIFICATE OF AMENDMENT OF BY-LAWS OF CALIFORNIA INVESTMENT TRUST The undersigned Trustees of California Investment Trust, a Massachusetts business trust (the "Trust"), constituting at least a majority of the Trustees of the Trust, do hereby certify and consent to the following: 1.

DEFR14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. 1) Filed by the registrant: /x/ Filed by a party other than the registrant: / / Check the appropriate box: / / Preliminary proxy statement / / Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(

DEF 14A

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the registrant: /x/ Filed by a party other than the registrant: / / Check the appropriate box: / / Preliminary proxy statement / / Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2

PRE 14A

PRE 14A 1 v038103pre14a.txt UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the registrant: /x/ Filed by a party other than the registrant: / / Check the appropriate box: /x/ Preliminary proxy statement / / Confidential, for Use of the Commission Only (as

EX-99.CERT

I, Stephen C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by

N-Q

N-Q 1 v033763n-q.txt As filed with the Securities and Exchange Commission on January 30, 2006 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file numbers:033-00499 and 811-04417 California Investment Trust - (Exact name of registrant as specified in charter)

N-Q

As filed with the Securities and Exchange Commission on July 29, 2005 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

EX-99.CERT

I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

NT-NCSR

NT-NCSR 1 v017790nt-ncsr.txt - SEC FILE NUMBER - CUSIP NUMBER - UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM 12b-25 NOTIFICATION OF LATE FILING (Check one): || Form 10-K || Form 20-F || Form 11-K || Form 10-Q || Form N-SAR |X| Form N-CSR For Period Ended: February 28, 2005 || Transition Report on Form 10-K || Transition Report on Form 20-F || Transition Report on Fo

N-Q

As filed with the Securities and Exchange Commission on January 31, 2005 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

EX-99.CERT

I, Steve C. Rogers, certify that: 1. I have reviewed this report on Form N-Q of California Investment Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by th

EX-99.77Q3

"Exhibit A" Form N-SAR Certification We, Steve Rogers and Phillip McClanahan, certify that: 1.

N-SAR (6.1)

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