[Letterhead]
[First Data Investor Services Group, Inc.]
[3200 Horizon Drive]
[P.O. Box 61503]
[King of Prussia, PA 19406]
October 28, 1999
VIA EDGAR
Securities and Exchange Commission
Judiciary Plaza, 450 Fifth Street, NW
Washington, DC 20549
RE: Kelmoore Strategic Trust (the "Trust");
File No's 333-69365 and 811-9165
Ladies and Gentlemen
Pursuant to Rule 497(j) under the Securities Act of 1933, as amended, please
accept this letter as certification that the prospectus and statement of
additional information for the Trust does not differ from that contained in
Post-Effective Amendment No. 2 (the "Amendment") to the Trust's Registration
Statement on Form N-1A. This Amendment was filed electronically on October 22,
1999.
Thank you for your ongoing considerations and cooperation. Please contact the
undersigned at (610) 239-4754 with any questions you may have.
Best regards,
/s/David Peters
________________________
David Peters
Compliance Administrator