TOWER MUTUAL FUNDS
5800 Corporate Drive
Pittsburgh, Pennsylvania 15237-7010
February 25, 1998
EDGAR Operations Branch
Securities and Exchange Commission
Division of Investment Management
450 Fifth Street, Northwest
Washington, DC 20549
RE: TOWER MUTUAL FUNDS (the "Registrant")
1933 Act File No. 33-21321
1940 ACT FILE NO. 811-5536
Dear Sir or Madam:
On behalf of Tower Mutual Funds (the "Registrant"), I hereby submit this
application for withdrawal of Post-Effective Amendment No. 18, which was filed
pursuant to Rule 485(b) under the Securities Act of 1933 (the "Act"), to the
Registrant's Registration Statement on Form N-1A.
The Rule 485(b) filing was made in order to add Class B Shares to the
Registrant's Tower Cash Reserve Fund's (the "Fund") portfolio. The existing Fund
class will be redesignated as Class A Shares. The effective date on
Post-Effective Amendment No. 18 was incorrect; therefore, please issue an order
with respect to this application for withdrawal at the earliest date the Staff
deems appropriate.
The Registrant intends to refile an Amendment to add the Class B Shares to
the Fund pursuant to Rule 485(b) with an effective date of March 11, 1998. The
information to be filed in such Rule 485(b) Amendment will be identical to the
information that was filed in Post-Effective Amendment No 18 on February 24,
1998.
Pursuant to the requirements of Rule 478 of the Act, this application for
withdrawal of the Amendment has been signed by the Assistant Secretary and Agent
for Service of the Registrant this 25th day of February, 1998.
If you have any questions regarding this application for withdrawal,
please contact Antoinette D. Brkovich at (412) 288-7420.
Very truly yours,
/s/ Gail Cagney
Gail Cagney
Assistant Secretary and Agent for
Service of Tower Mutual Funds
