THE TOPIARY FUND FOR BENEFIT PLAN INVESTORS (BPI) LLC 25 De Forest Avenue Summit, New Jersey 07901 September 30, 2004 Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Attention: Division of Investment Management Re: The Topiary Fund for Benefit Plan Investors (BPI) LLC Pre-Effective Amendment No. 3 to the Registration Statement on Form N-2A (File Nos. 333-111561 and 811-21480) ----------------------------------------------------- Ladies and Gentleman: Pursuant to Rule 497(j) under the Securities Act of 1933, as amended (the "1933 Act"), The Topiary Fund for Benefit Plan Investors (BPI) LLC, (the "Fund') hereby certifies that: 1. the form of Prospectus and Statement of Additional Information that would have been filed pursuant to Rule 497(c) under the 1933 Act would not have differed from that contained in Pre-Effective Amendment No. 3 to the Fund's Registration Statement on Form N-2A; 2. the text of Pre-Effective Amendment No. 3 to the Fund's Registration Statement on Form N-2A was filed electronically with the Securities and Exchange Commission on September 14, 2004. Very truly yours, The Topiary Fund for Benefit Plan Investors (BPI) LLC By: * ----------------------- Name: Natalie Birrell Title: President * By: /s/ Elizabeth Keeley -------------------- Elizabeth Keeley, as attorney-in-fact