PACIFIC CAPITAL FUNDS
NSAR-B, EX-99, 2000-09-28
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Report of Independent Auditors
To the Shareholders and
Board of Trustees of Pacific Capital Funds

In planning and performing our audit of the financial statements
of Pacific Capital Funds for the year ended July 31, 2000, we
considered its internal control, including control activities for
safeguarding securities, in order to determine our auditing
procedures for the purpose of expressing our opinion on the
financial statements and to comply with the requirements of
Form N-SAR, not to provide assurance on internal control.

The management of Pacific Capital Funds is responsible for
establishing and maintaining internal control.  In fulfilling
this responsibility, estimates and judgments by management
are required to assess the expected benefits and related costs
of controls.  Generally, controls that are relevant to an audit
pertain to the entity's objective of preparing financial statements
for external purposes that are fairly presented in conformity with
generally accepted accounting principles.  Those controls include
the safeguarding of assets against unauthorized acquisition, use
or disposition.

Because of inherent limitations in internal control, error or fraud
may occur and not be detected.  Also, projection of any evaluation
of internal control to future periods is subject to the risk that it
may become inadequate because of changes in conditions or that
the effectiveness of the design and operation may deteriorate.

Our consideration of internal control would not necessarily
disclose all matters in internal control that might be material
weaknesses under standards established by the American
Institute of Certified Public Accountants.  A material weakness
is a condition in which the design or operation of one or more
of the internal control components does not reduce to a relatively
low level the risk that misstatements caused by error or fraud in
amounts that would be material in relation to the financial
statements being audited may occur and not be detected within
a timely period by employees in the normal course of performing
their assigned functions.  However, we noted no matters involving
internal control and its operation, including controls for safeguarding
securities, that we consider to be material weaknesses as defined
above at July 31, 2000.

This report is intended solely for the information and use of
management, the Board of Trustees of Pacific Capital Funds,
and the Securities and Exchange Commission and is not intended
to be and should not be used by anyone other than these specified
parties.

/s/Ernst & Young LLP
Columbus, Ohio
September 20, 2000



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