The Vintage Funds
429 North Pennsylvania Street
Indianapolis, Indiana 46204
FILED VIA EDGAR
January 25, 1996
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Kathy L. Tewey, Accountant,
Division of Investment Management
Re: The Vintage Funds;
FILE NOS. 33-89078 AND 811-8968
Ladies and Gentlemen:
Pursuant to Rule 477(a) under the Securities Act of 1933, as
amended (the "1933 Act"), The Vintage Funds (the "Fund") hereby applies for
withdrawal of Post-Effective Amendment No. 3 to the Fund's Registration
Statement on Form N-1A filed January 8, 1996 (the "Amendment").
As Jeff Brown of Baker & Daniels, the Fund's counsel, has
discussed telephonically with Kathy Tewey of the Division of Investment
Management, the Amendment was filed prematurely without the review of
counsel and without incorporating responses to Ms. Tewey's comments on
Post-Effective Amendment No. 2 to the Registration Statement filed in
November 1995. Moreover, the Amendment was erroneously filed pursuant to
Rule 485(a), rather than Rule 485(b), under the 1933 Act. On or before
January 29, 1996, the Fund intends to re-file Post-Effective No. 3 to the
Registration Statement to reflect Ms. Tewey's comments and certain other
material changes to the Registration Statement, pursuant to Rule 485(b)
under the 1933 Act.
Given the timeframe involved with this application, the Fund
respectfully requests that this application be granted as soon as possible.
Thank you and, should there be any questions regarding this matter, please
contact Jeff Brown of Baker & Daniels at (317) 237-1113.
Very truly yours,
THE VINTAGE FUNDS
By: /S/ TIMOTHY L. ASHBURN
Timothy L. Ashburn
President
