July 27, 1994
Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
Re: Rule 24f-2 Notice for
CUNA Mutual Funds, Inc.
100 East Pratt Street
Baltimore, Maryland 21202
File Number 33-50549
Gentlemen:
In accordance with the provisions of Rule 24f-2, the CUNA Mutual Funds,
Inc. hereby files its Rule 24f-2 Notice on behalf of its CUNA Mutual U.S.
Government Income Fund ("U.S. Government Income Fund"), CUNA Mutual
Cornerstone Fund ("Cornerstone Fund") and CUNA Mutual Tax-Free Intermediate-
Term Fund ("Tax-Free Intermediate-Term Fund"). <PAGE>
This "Rule 24f-2 Notice" is being filed for the fiscal year beginning
December 30, 1993 and ending May 31, 1994 ("Fiscal Year") for the U.S.
Government Income, Cornerstone and Tax-Free Intermediate-Term Funds.
224,271, 249,627 and 222,671 shares of common stock of the U.S.
Government Income, Cornerstone and Tax-Free Intermediate-Term Funds,
respectively, were sold during the Fiscal Year.
All 224,271, 249,627 and 222,671 shares of common stock of the U.S.
Government Income, Cornerstone and Tax-Free Intermediate-Term Funds were sold
during the Fiscal Year in reliance upon the Declaration of the Funds of an
indefinite amount of securities under Rule 24f-2 ("24f-2 Declaration").
Attached to this Rule 24f-2 Notice, and made a part hereof, is an opinion
of counsel indicating that the securities, the registration of which the
Notice makes definite in number, were legally issued, fully paid, and
non-assessable.
In accordance with subsection (c) of Rule 24f-2, the registration fees in
the amounts of $770.44, $856.83 and $765.05 for the U.S. Government Income,
Cornerstone and Tax-Free Intermediate-Term Funds, respectively, have been
forwarded to Mellon Bank, Pittsburgh, Pennsylvania. The fee computations are
based upon the actual aggregate sale price for which such securities were sold
during the Fiscal Year, reduced by the difference between:
<PAGE>
(1) The actual aggregate redemption price of the shares
redeemed by the Fund during the Fiscal Year, and
(2) The actual aggregate redemption price of such
redeemed shares previously applied by the Fund
pursuant to Rule 24e-2(a) in filings made pursuant
to Section 24(e)(1) of the Investment Company Act of
1940.
U.S. Government Cornerstone
Income Fund Fund
Aggregate Sale Price for
Shares Sold During Fiscal
Year in Reliance Upon
the 24f-2 Declaration $ 2,238,779 $ 2,487,222
Reduced by the Difference Between
(1) Aggregate Redemption
Price of Shares
Redeemed During the
Fiscal Year $ 4,531 $ 2,440
and,
(2) Aggregate Redemption
Price of Redeemed Shares
Previously Applied by Fund
Pursuant to Rule 24e-2(a)
Filings Made Pursuant to
Section 24(e)(1) of
Investment Company
Act of 1940 $ - 0 - $ - 0 -
Equals $ 2,234,248 $ 2,484,782
<PAGE>
(1) The actual aggregate redemption price of the shares
redeemed by the Fund during the Fiscal Year, and
(2) The actual aggregate redemption price of such
redeemed shares previously applied by the Fund
pursuant to Rule 24e-2(a) in filings made pursuant
to Section 24(e)(1) of the Investment Company Act of
1940.
Tax-Free
Intermediate-Term
Fund
Aggregate Sale Price for
Shares Sold During Fiscal
Year in Reliance Upon
the 24f-2 Declaration $2,221,017
Reduced by the Difference Between
(1) Aggregate Redemption
Price of Shares
Redeemed During the
Fiscal Year $ 2,400
and,
(2) Aggregate Redemption
Price of Redeemed Shares
Previously Applied by Fund
Pursuant to Rule 24e-2(a)
Filings Made Pursuant to
Section 24(e)(1) of
Investment Company
Act of 1940 $ - 0 -
Equals $2,218,617
Any questions regarding the matter should be addressed to
Henry H. Hopkins, Esquire at the above address.
Very truly yours,
/s/ CARMEN F. DEYESU
July 27, 1994
CUNA Mutual Funds, Inc.
100 East Pratt Street
Baltimore, Maryland 21202
Dear Sirs:
CUNA Mutual Funds, Inc., a Maryland corporation (the "Corporation"), is
filing with the Securities and Exchange Commission a Rule 24f-2 Notice on
behalf of its Sub-Funds, CUNA Mutual U.S. Government Income Fund ("U.S.
Government Income Fund"), CUNA Mutual Cornerstone Fund ("Cornerstone Fund")
and CUNA Mutual Tax-Fee Intermediate-Term Fund ("Tax-Free Intermediate-Term
Fund") containing the information specified in paragraph (b)(1) of Rule 24f-2
under the Investment Company Act of 1940 (the "Rule"). The effect of the Rule
24f-2 Notice, when accompanied by this Opinion and by the filing fee, if any,
payable as prescribed by paragraph (c) of the Rule will be to make definite
the number of shares sold by the U.S. Government Income Fund, the Cornerstone
Fund and the Tax-Free Intermediate-Term Fund during the fiscal year beginning
December 30, 1993 and ending May 31, 1994 in reliance upon the Rule, if any
(the "Rule 24f-2 Shares").
We have, as counsel, participated in various corporate and other
proceedings relating to the Corporation and to the Rule 24f-2 Shares. We have
examined copies, either certified or otherwise proven to our satisfaction to
be genuine, of its Charter and By-Laws, as currently in effect, and a
certificate dated July 12, 1994 issued by the Department of Assessments and
Taxation of the State of Maryland certifying the existence and good standing
of the Corporation. We have also reviewed the Corporation's Registration
Statement on Form N-1A and the form of the Rule 24f-2 Notice being filed by
the Corporation. We are generally familiar with the corporate affairs of the
Corporation.
The Corporation has advised us that the Rule 24f-2 Shares were sold in
the manner contemplated by the prospectus of the Corporation that was current
and effective under the Securities Act of 1933 at the time of sale, and that
the Rule 24f-2 Shares were sold in numbers within the limits prescribed by the
Charter of the Corporation for a consideration not less than the par value
thereof as required by the laws of Maryland and not less than the net asset
value thereof as required by the Investment Company Act of 1940.
Based upon the foregoing, it is our opinion that:
1. The Corporation has been duly organized and is legally existing
under the laws of the State of Maryland.
2. The Corporation is authorized to issue one billion (1,000,000,000)
shares of Common Stock, par value ($.0001) per share. Under Maryland law, (a)
the number of authorized shares may be increased or decreased by action of the
Board of Directors and (b) shares which were issued and which have
subsequently been redeemed by the Corporation are, by virtue of such
redemption, restored to the status of authorized and unissued shares.
3. The Rule 24f-2 Shares were legally issued and are fully paid and
non-assessable.
We hereby consent to the filing of this Opinion with the Securities and
Exchange Commission together with the Rule 24f-2 Notice of the Corporation,
and to the filing of this Opinion under the securities laws of any state.
We are members of the Bar of the State of New York and do not hold
ourselves out as being conversant with the laws of any jurisdiction other than
those of the United States of America and the State of New York. We note that
we are not licensed to practice law in the State of Maryland, and to the
extent that any opinion expressed herein involves the law of Maryland, such
opinion should be understood to be based solely upon our review of the
documents referred to above, the published statutes of that State and, where
applicable, published cases, rules or regulations of regulatory bodies of that
State.
Very truly yours,
Shereff, Friedman, Hoffman & Goodman
