DECHERT PRICE & RHOADS Letterhead
Ten Post Office Square, South
Boston, Massachusetts 02109
(617)728-7100
(617)426-6567 (fax no.)
January 6, 2000
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn: Mrs. Patricia P. Williams
Division of Investment Management
Re: Withdrawal of Registration Statement
of The Universal Funds (the "Trust")
FILE NOS. 811-9627 AND 333-88937
Dear Mrs. Williams:
Pursuant to Rule 477(a) under the Securities Act of 1933, as amended
(the "1933 Act"), the Trust hereby submits this application (the "Application")
for an order of the Securities and Exchange Commission (the "SEC") granting
withdrawal of the Trust's registration statement filed under the 1933 Act and
the Investment Company Act of 1940, as amended (the "1940 Act"), on October 13,
1999. At this time, the Trust's sponsor, Ivy Management, Inc., has determined
that the Trust does not comport with its plans for new product development,
although it may pursue registration of a similar product in the future. In
support of this Application, the Trust states that it has never made a public
offering of securities; that it is not now nor has it ever been active; and that
it has no assets, known liabilities or pending claims. The Trust believes that
withdrawal of its registration statement would be consistent with the public
interest and the protection of investors. No fees are required in connection
with this filing.
On October 13, 1999, the Trust filed via EDGAR its notification of
registration pursuant to Section 8(a) of the 1940 Act on Form N-8A. Accordingly,
concurrently with this Application the Trust is filing with the SEC on Form N-8F
an application for an order pursuant to Section 8(f) of the 1940 Act declaring
that the Trust has ceased to be an investment company.
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Please contact the undersigned at (617) 728-7161 or Eric C. Griffith
at (617)728-7113 with any questions concerning this filing.
Very truly yours,
/S/ JOSEPH R. FLEMING
Joseph R. Fleming,
Attorney-in-Fact
