RAVEN FUNDS
5800 Corporate Drive
Pittsburgh, Pennsylvania 15237-7010
September 1, 2000
EDGAR Operations Branch
Securities and Exchange Commission
Division of Investment Management
450 Fifth Street, Northwest
Washington, DC 20549
RE: RAVEN FUNDS ("Registrant")
RAVEN TREASURY MONEY MARKET FUND ("FUND")
Dear Sir or Madam:
Enclosed are the filing materials for a newly formed investment company
named "RAVEN FUNDS." The enclosed initial registration statement is filed on
Form N-1A pursuant to the Securities Act of 1933 and the Investment Company Act
of 1940. This Registration Statement and the red-herring Prospectus and
Statement of Additional Information for the Fund are being filed electronically.
The Registrant is a Delaware business trust, presently composed of the one
Portfolio noted above. The Fund is sold pursuant to a 12b-1 Distribution Plan.
The Registrant will be advised by Raven Asset Management, L.L.C.,
sub-advised by Federated Investment Research Company and distributed by Edgewood
Securities, Inc., a wholly owned subsidiary of Federated Investors, Inc.
The enclosed Registration Statement is substantially similar to Automated
Government Money Trust, a portfolio of Money Market Obligations Trust (1933 Act
No. 33-31602 and 1940 Act No.811-5950), which was previously reviewed by the
Securities and Exchange Commission and Advised by Federated Investment
Management Company, a wholly owned subsidiary of Federated Investors, Inc.
The Registrant respectfully request effectiveness as of September 26,
2000, or such time thereafter as the Staff deems appropriate. This is necessary
because the prospective shareholders of the Fund, which are American Indian
Tribes, expect to receive money in the form of housing grants from the
Department of Housing and Urban Development on or about October 1, 2000, a
portion of which may be invested in the Fund. Pursuant to the telephone
conversation between C. Grant Anderson, Esq. and Linda Stirling, we are asking
for comments by September 19, 2000 in order to meet production and printing
dates.
I will be pleased to furnish any further information which you may request
and would appreciate your immediate attention to this filing. Please feel free
to contact me at (412) 288-1097 or C. Grant Anderson at (412) 288-8160.
Very truly yours,
/s/ Heather M. Aland
Heather M. Aland
Senior Paralegal
