Reynolds Funds, Inc.
Wood Island, Third Floor
80 East Sir Francis Drake Boulevard
Larkspur, California 94939
November 15, 1995
Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
Attention: Mr. Frank Donaty
Re: Rule 24f-2 Notice for Reynolds Funds, Inc.
File #33-21718
Gentlemen:
Pursuant to Rule 24f-2 under the Investment Company Act of 1940,
the undersigned submits the following Rule 24f-2 Notice:
(1) This Rule 24f-2 Notice is filed for the Fiscal Year
ended September 30, 1995.
(2)-(3) No securities of the undersigned have ever been
registered under the Securities Act of 1933 other than pursuant
to Rule 24f-2.
(4)-(5) The amount of Common Stock, $0.01 par value, sold
pursuant to Rule 24f-2 during the fiscal year ended
September 30, 1995 for the Reynolds Blue Chip Growth Fund was
$4,751,898, for the Reynolds Money Market Fund was $6,711,496,
for the Reynolds Opportunity Fund was $3,063,971 and for the
Reynolds U.S. Government Bond Fund was $300,059, based on the
actual aggregate sales prices for such securities. The amount
of Common Stock, $0.01 par value, redeemed during the fiscal
year ended September 30, 1995 for the Reynolds Blue Chip Growth
Fund was $7,360,639, for the Reynolds Money Market Fund was
$6,160,428, for the Reynolds Opportunity Fund was $1,093,553 and
for the Reynolds U.S.Government Bond Fund was $1,925,062 based
on the actual redemption prices for such securities.
Pursuant to Rule 24f-2(c) no filing fee is payable because the
amount of Common Stock $0.01 par value redeemed during the fiscal year
ended September 30, 1995 was not less than the amount sold
([$4,751,898 + $6,711,496 + $3,063,971 + $300,059] = $14,827,424 less
[$7,360,639 + $6,160,428 + $1,093,553 + $1,925,062] = $16,539,682).
Attached is the required opinion of Foley & Lardner.
If you have any questions, please do not hesitate to call me.
Very truly yours,
Camille F. Wildes
Secretary
FOLEY & LARDNER
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WRITER'S DIRECT LINE
November 15, 1995
Reynolds Funds, Inc.
Wood Island, Third Floor
80 East Sir Francis Drake Boulevard
Larkspur, California 94939
Gentlemen:
We have acted as counsel for you in connection with the
preparation of a Registration Statement on Form N-1A and amendments
thereto relating to the sale by you of an indefinite amount of Reynolds
Funds, Inc. Common Stock, $.01 par value (such Common Stock being
hereinafter referred to as the "Stock"), in the manner set forth in the
Registration Statement. In this connection, we have examined: (a) the
Registration Statement on Form N-1A and all amendments thereto; (b) the
Rule 24f-2 Notice for each of Reynolds Blue Chip Growth Fund, Reynolds
Money Market Fund, Reynolds U.S. Government Bond Fund and Reynolds
Opportunity Fund series of Reynolds Funds, Inc. dated November 15, 1995;
(c) corporate proceedings relative to the authorization for issuance of
shares of the Stock; and (d) such other proceedings, documents and records
as we deemed necessary to enable us to render this opinion.
Based on the foregoing, we are of the opinion that the shares of
Stock sold in the fiscal year ended September 30, 1995 in reliance upon
registration pursuant to Rule 24f-2 under the Investment Company Act of
1940 and in the manner set forth in the Registration Statement were
legally issued, fully paid and nonassessable. We have not examined the
stock register books of the Reynolds Blue Chip Growth Fund, Reynolds Money
Market Fund, Reynolds U.S. Government Bond Fund and Reynolds Opportunity
Fund series of Reynolds Funds, Inc. In opining that the shares of Stock
sold in the fiscal year ended September 30, 1995 were fully paid, we have
relied upon a certificate of an officer of Reynolds Funds, Inc. as to the
consideration received for such shares.
We hereby consent to the use of this opinion in connection with
the filing of the Rule 24f-2 Notice for Reynolds Funds, Inc. for its
fiscal year ended September 30, 1995. In giving this consent, we do not
admit that we are experts within the meaning of Section 11 of the
Securities Act of 1933, as amended, or within the category of persons
whose consent is required by Section 7 of said Act.
Very truly yours,
FOLEY & LARDNER
