SEC Info - Capita Corp, et al. - ‘CORRESP’ from 10/27/09

CIT GROUP INC.
505 Fifth Avenue
New York, NY 10017

October 27, 2009

VIA EDGAR AND FACSIMILE (703) 813-6983

Mark Webb, Esq.
Justin Dobbie, Esq.
United States Securities and Exchange Commission
Division of Corporate Finance
Mail Stop 4720
100 F. Street, N.E.
Washington, DC 20549

Re: Request for Effectiveness of Application for Qualification of Indenture on Form T-3 (File No. 022-28906)

Dear Messrs. Webb and Dobbie:

In accordance with Section 307 of the Trust Indenture Act and the rules promulgated thereunder, the undersigned applicants hereby request that the effective date for the Application for Qualification of Indenture on Form T-3 referred to above be accelerated so that it will be declared effective at 4:30 p.m., Eastern Standard Time, on Thursday, October 29, 2009, or as soon thereafter as is practicable.

We acknowledge that:

		(a) Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;


		(b) The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and


		(c) The Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Thank you for your assistance in this matter.

C: C: C: C:



		Very truly yours,

		CIT GROUP INC.

		By: /s/ *Glenn A. Votek*
		Name: Glenn A. Votek
		Title: Executive Vice President and Treasurer

		CIT GROUP FUNDING COMPANY OF DELAWARE LLC

		By: /s/ *Glenn A. Votek*
		Name: Glenn A. Votek
		Title: President and Treasurer

Mark Webb, Esq.
Justin Dobbie, Esq.
October 27, 2009
Page 2


		BAFFIN SHIPPING CO., INC.
		C.I.T. LEASING CORPORATION
		CAPITA COLOMBIA HOLDINGS CORP.
		CAPITA CORPORATION
		CAPITA INTERNATIONAL L.L.C.
		CAPITA PREMIUM CORPORATION
		CIT CAPITAL USA INC.
		CIT CHINA 12, INC.
		CIT CHINA 13, INC.
		CIT CHINA 2, INC.
		CIT CHINA 3, INC.
		CIT COMMUNICATIONS FINANCE CORPORATION
		CIT CREDIT FINANCE CORP.
		CIT CREDIT GROUP USA INC.
		CIT FINANCIAL LTD. OF PUERTO RICO
		CIT FINANCIAL USA, INC.
		CIT GROUP (NJ) LLC
		CIT GROUP SF HOLDING CO., INC.
		CIT HEALTHCARE LLC
		CIT HOLDINGS, LLC
		CIT LENDING SERVICES CORPORATION
		CIT LENDING SERVICES CORPORATION (ILLINOIS)
		CIT LOAN CORPORATION (F/K/A THE CIT GROUP/CONSUMER FINANCE, INC.)
		CIT REALTY LLC
		CIT TECHNOLOGIES CORPORATION
		CIT TECHNOLOGY FINANCING SERVICES, INC.
		EDUCATION LOAN SERVICING CORPORATION
		EQUIPMENT ACCEPTANCE CORPORATION
		FRANCHISE PORTFOLIO 1, INC.
		FRANCHISE PORTFOLIO 2, INC.
		GFSC AIRCRAFT ACQUISITION FINANCING CORPORATION
		HUDSON SHIPPING CO., INC.
		NAMEKEEPERS LLC
		OWNER-OPERATOR FINANCE COMPANY
		STUDENT LOAN XPRESS, INC.
		THE CIT GROUP/BC SECURITIES INVESTMENT, INC.
		THE CIT GROUP/BUSINESS CREDIT, INC.
		THE CIT GROUP/CAPITAL FINANCE, INC.
		THE CIT GROUP/CAPITAL TRANSPORTATION, INC.
		THE CIT GROUP/CMS SECURITIES INVESTMENT, INC.
		THE CIT GROUP/COMMERCIAL SERVICES, INC.
		THE CIT GROUP/COMMERCIAL SERVICES, INC. (VA)
		THE CIT GROUP/CONSUMER FINANCE, INC. (NY)
		THE CIT GROUP/CONSUMER FINANCE, INC. (TN)
		THE CIT GROUP/CORPORATE AVIATION, INC.
		THE CIT GROUP/EQUIPMENT FINANCING, INC.
		THE CIT GROUP/EQUITY INVESTMENTS, INC.
		THE CIT GROUP/FACTORING ONE, INC.
		THE CIT GROUP/FM SECURITIES INVESTMENT, INC.
		THE CIT GROUP/LSC SECURITIES INVESTMENT, INC.
		THE CIT GROUP/SECURITIES INVESTMENT, INC.
		THE CIT GROUP/VENTURE CAPITAL, INC.
		WESTERN STAR FINANCE, INC.

		By: /s/ *Glenn A. Votek*
		Name: Glenn A. Votek
		Title: Executive Vice President

Mark Webb, Esq.
Justin Dobbie, Esq.
October 27, 2009
Page 3


		CIT REAL ESTATE HOLDING CORPORATION

		By: /s/ *Glenn A. Votek*
		Name: Glenn A. Votek
		Title: Treasurer

This ‘CORRESP’ Filing	Date	Other Filings

Release Delayed to:	12/14/09	4, UPLOAD
	10/29/09	8-K, CORRESP, UPLOAD
Filed on:	10/27/09
		List all Filings

Capita Corp, et al. – ‘CORRESP’ from 10/27/09

On: Tuesday, 10/27/09, at 5:24pm ET · Private-to-Public: Filing `¶` – Release Delayed to: 12/14/09 · Accession #: 950123-9-53744

Delayed-Release Comment-Response or Other Letter to the SEC
Filing Table of Contents

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Dates Referenced Herein and Documents Incorporated by Reference

Capita Corp, et al. – ‘CORRESP’ from 10/27/09

On: Tuesday, 10/27/09, at 5:24pm ET · Private-to-Public: Filing ¶ – Release Delayed to: 12/14/09 · Accession #: 950123-9-53744

Delayed-Release Comment-Response or Other Letter to the SECFiling Table of Contents

This is an HTML Document rendered as filed. [ Alternative Formats ]

Dates Referenced Herein and Documents Incorporated by Reference

On: Tuesday, 10/27/09, at 5:24pm ET · Private-to-Public: Filing `¶` – Release Delayed to: 12/14/09 · Accession #: 950123-9-53744

Delayed-Release Comment-Response or Other Letter to the SEC
Filing Table of Contents