Aetna Funds
10 State House Square, SH11
Hartford, Connecticut 06103-3602
November 28, 2000
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn: Ms. Mary Cole
Division of Investment Management
Re: Request for Withdrawal of Post-Effective Amendment No. 45 to
the Registration Statement on Form N-1A of Aetna Series
Fund, Inc. (the "Fund") File Nos. 33-41694 and 811-6352
Dear Ms. Cole:
Pursuant to Rule 477(a) (the "Rule") under the Securities Act of 1933,
as amended, I hereby request on behalf of the Fund that the Securities and
Exchange Commission (the "Commission") withdraw Post-Effective Amendment No. 45
to the Fund's Registration Statement on Form N-1A (the "Amendment"). The
Amendment was filed with the Commission on September 29, 2000 (accession no.
0000949377-00-000578) for the purpose of adding a new series to the Fund, namely
Aetna Index Plus Protection Fund II (the "Series").
The Fund has determined that, at this time, the Series does not
comport with its immediate business plans. Accordingly, the Fund has no present
intention of initiating operations or offering shares of the Series and would
like to avoid costs associated with adding the Series, although it intends to
pursue registration of a similar series in the future. In support of its
request, the Fund states that it has never made a public offering of securities
of the Series, that the Series is not now nor has it ever been active, and that
the Series has no assets, known liabilities or pending claims. The Fund believes
that, in accordance with the Rule, withdrawal of this Amendment would be
consistent with the public interest and the protection of investors.
If the Commission consents to the withdrawal, I would request that a
copy of the Commission's order granting the withdrawal be forwarded to my
attention at the address listed above. Please direct any questions you may have
with respect to this application to me at (860)275-2168.
AETNA SERIES FUND, INC.
/s/Daniel E. Burton
Secretary and Agent for Service