Deutsche Investment Management Americas Inc.
One Beacon Street
Boston, MA 02108
January 29, 2016
VIA EDGAR
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Marianne Dobelbower
| Re: | Post-Effective Amendment No. 62 to the Registration Statement on Form N-1A of Treasury Portfolio (the “Fund”), a series of Investors Cash Trust (the “Trust”) (Reg. Nos. 033-34645; 811-06103) |
Dear Ms. Dobelbower,
This letter is being submitted on behalf of the Fund in response to comments of the Staff of the Securities and Exchange Commission (the “Commission”) received via a telephone call on January 20, 2016 with regard to the above-captioned Post-Effective Amendment filed on behalf of the Fund on December 3, 2015 with an effective date of February 1, 2016.
The Staff’s comments are restated below followed by the Fund’s responses.
| 1. | Comment: Please explain whether the contractual or voluntary expense waiver/reimbursement arrangements reflected in the Fund’s prospectus provide for the recoupment of fees beyond the period. If such expense waiver/reimbursement provides for such recoupment, please add appropriate disclosure to the Fund’s prospectus. |
Response: The Fund’s contractual and voluntary expense waiver/reimbursement arrangements do not provide for the recoupment of fees beyond the period.
| 2. | Comment: Please confirm that the expense example does not reflect the expense waiver/reimbursement in place for one year since such waiver/reimbursement is not shown in the expense table. |
Response: The Fund confirms that the expense example in the summary section of the prospectus does not reflect any expense waiver/reimbursement.
If you have any questions regarding any of the foregoing or require additional information, please call me at (617) 295-3986.
Sincerely yours,
/s/Scott D. Hogan
Scott D. Hogan
Director and Senior Counsel
cc. John Marten, Vedder Price