GODFREY & KAHN, S.C.
ATTORNEYS AT LAW
780 North Water Street
Milwaukee, Wisconsin 53202
Phone (414) 273-3500 Fax (414) 273-5198
December 26, 2000
VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: STRONG SHORT-TERM MUNICIPAL BOND FUND, INC.
Ladies and Gentlemen:
We represent Strong Short-Term Municipal Bond Fund, Inc. (the
"Company"), in connection with its filing of Post-Effective Amendment No. 16
(the "Post-Effective Amendment") to the Company's Registration Statement
(Registration Nos. 33-42773; 811-6409) on Form N-1A under the Securities Act of
1933 (the "Securities Act") and the Investment Company Act of 1940. The
Post-Effective Amendment is being filed pursuant to Rule 485(b) under the
Securities Act.
We have reviewed the Post-Effective Amendment and, in accordance with
Rule 485(b)(4) under the Securities Act, hereby represent that the
Post-Effective Amendment does not contain disclosures which would render it
ineligible to become effective pursuant to Rule 485(b).
We consent to the use of this letter in the Post-Effective Amendment.
Very truly yours,
GODFREY & KAHN, S.C.
/s/ Ellen Drought
Ellen Drought
