Securities Law & Instruments


IN THE MATTER OF THE COMMODITY FUTURES ACT
R.S.O. 1990, CHAPTER C. 20, AS AMENDED (the "Act")

AND

IN THE MATTER OF
HARRIS INVESTMENT MANAGEMENT INC.

ORDER
(Section 38)


UPON the application of Harris Investment Management Inc. (the "Applicant") foran order, pursuant to section 38 of the Act, exempting the Applicant from therequirement to obtain registration as an adviser under clause 22(1)(b) of the Act;

AND UPON considering the application and the recommendation of the staff ofthe Commission;

AND UPON the Applicant having represented to the Commission as follows.

1. The Applicant was incorporated under the laws of the State of Delaware in 1989and conducts its business as a portfolio manager from its offices in Chicago,Illinois.

2. The Applicant is registered with the Securities and Exchange Commission of theUnited States ("U.S."), as an adviser under the Investment Advisors Act of 1940.The Applicant is also registered with the Commodity Futures TradingCommission under the Commodity Exchange Act for derivatives and futurestrading.

3. The Applicant is registered with the Commission under the Securities Act(Ontario) (the "Securities Act") as an adviser in the category of internationaladviser.

4. The Applicant is the portfolio manager of the BMO RSP U.S. Equity Index Fundand the BMO U.S. Dollar Equity Index Fund (together, the "Funds"). Each of theFunds is an open-end mutual fund trust established under the laws of theprovince of Ontario pursuant to separate declarations of trust.

5. Each of the Funds is a "reporting issuer" within the meaning of the SecuritiesAct, and neither one of them is in default of the requirements of Ontariosecurities law. The units of each Fund are qualified for sale and distribution ineach of the provinces and territories of Canada pursuant to a simplifiedprospectus and annual information form dated March 9, 1999 (together, the"Prospectus"), the lapse date of which was March 12, 2000.

6. The Funds have filed their pro forma simplified prospectus and annualinformation form and have obtained an extension on the lapse date to April 14,2000.

7. The investment objective of each Fund is to achieve long-term growth bytracking the performance of Standard & Poor's 500 Total Return Index (the"Index") and invest primarily in options and futures contracts based on theIndex.

8. In order for the Applicant to advise the Funds as to trading in futures contracts, itmust be registered as an adviser pursuant to clause 22(1)(b) of the Act.

9. In the past, the Applicant relied on the registration exemption provided for byclause 31(d) of the Act. Staff of the Commission have informed the Applicant thatit is not appropriate to continue to rely on the statutory exemption.

10. The Applicant has agreed to apply for registration as an adviser under the Act inorder to continue to act as portfolio manager of the Funds. However, theapplication process may not be completed prior to the date on which a receipt forthe renewal prospectus of the Funds must be issued so that the Funds' units cancontinue to be offered in all of the provinces and territories of Canada.

11. It is in the best interests of the unitholders of the Funds that the Funds not sufferany interruption in the offering of their units to the public, and that the Applicantbe allowed to continue the management of the investment portfolios of the Fundsduring the time required for the Applicant to complete the registration process.

AND UPON the Commission being satisfied that to do so would not beprejudicial to the public interest;

IT IS ORDERED pursuant to section 38 of the Act that the Applicant be exemptfrom the registration requirement of subsection 22(1)(b) of the Act provided that:

(a) the Applicant forthwith files an application to obtain registration as an adviserunder the Act; and

(b) this order will expire on the earlier of the date that the Applicant is grantedregistration and the expiry of six months from the date of this order.

April 7th, 2000.

"Howard I. Wetston"      "K. D. Adams"