[LETTERHEAD OF THE SBI FUND, INC.]
October 14, 1998
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Attention: Frank J. Donaty, Jr.
Assistant Director
Re: The SBI Fund, Inc.
Registration Statement on Form N-1A (No. 33-67652)
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Ladies and Gentlemen:
Pursuant to Rule 477 of the Securities Act of 1933, as
amended, The SBI Fund, Inc. (the "Fund") hereby requests withdrawal of its
above-referenced Registration Statement on Form N-1A filed under the Securities
Act of 1933, as amended, and the Investment Company Act of 1940, as amended. The
Fund has determined that it will not commence operations at this time, however,
it intends to file a new registration statement at such time as it determines to
start operations.
If you require anything further in order to effect the
withdrawal of the Registration Statement, please contact me at (850) 561-2661 or
Sherri Reiss of Wachtell, Lipton, Rosen & Katz at (212) 403-1315.
THE SBI FUND, INC.
By:/s/ DARRELL R. WILLIAMS
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Darrell R. Williams, President
