Argues that functional categories instantiated in the learners' first language (L1) transfer to the initial state of second language syntactic development. On the basis of Zulu interlanguage data on acquisition of the obligatory declarative complementizer "ukuthi" (that) by English native speakers, argues that Comp contains a null complementizer system that has sufficient syntactic content to generate subordination in learners' initial Zulu interlanguage grammar. (Author/VWL)