newcov_corresp.htm
November
25, 2008
BY
EDGAR
Mr. Brick
Barrientos
Securities
and Exchange Commission
100 “F”
Street, N.E.
Washington,
DC 20549
Re: Acceleration
of Effectiveness Request
New
Covenant Funds (the “Trust”)
File
Nos.: 333-64981 and 811-09025
Accession No.:
0000894189-08-003684
Dear Mr.
Barrientos:
On behalf
of the Trust and its series, the New Covenant Growth Fund, the New Covenant
Income Fund and the New Covenant Balanced Income Fund (the “Funds”), we hereby
request acceleration of the registration statement filed on November 24, 2008,
on Form N-1A under the Securities Act of 1933, as amended (the “1933 Act”)
as Post-Effective Amendment No. 11 (the “Amendment”) and the Investment Company
Act of 1940, as amended (the “1940 Act”) as Post-Effective Amendment No. 13
so that the registration statement on Form N-1A would be declared effective on
November 26, 2008.
This
filing was made for the sole purpose of establishing series and class
identifiers for the series of the Trust in existence prior to February 6,
2006.
Pursuant
to the Securities and Exchange Commission’s authority under Rule 461(a) and
Rule 488(a) of the General Rules and Regulations under the 1933 Act, we
have attached as a separate letter from New Covenant Funds Distributor, Inc.,
the Fund’s principal underwriter, requesting that effectiveness of the Amendment
to the registration statement be accelerated to Wednesday, November 26, 2008, or
as soon as practicable thereafter.
Very
truly yours,
/s/ Jeanine M.
Bajczyk
Jeanine
M. Bajczyk, Esq.
for U.S.
Bancorp Fund Services, LLC
Enclosure
NEW
COVENANT FUNDS DISTRIBUTOR, INC. [letterhead]
November
25, 2008
BY
EDGAR
Securities
and Exchange Commission
100 “F”
Street, N.E.
Washington,
DC 20549
Ladies
and Gentlemen:
New
Covenant Funds
REQUEST
FOR ACCELERATION. As the principal underwriter of the New Covenant
Growth Fund, the New Covenant Income Fund, and the New Covenant Balanced Income
Fund (the “Funds”), and pursuant to the Securities and Exchange Commission’s
authority under Rule 461(a) and Rule 488(a) of the General Rules and Regulations
under the Securities Act of 1933, we request that effectiveness of the
Registration Statement filed on Form N-1A on behalf of the Fund on November 24,
2008, be accelerated to Wednesday, November 26, 2008, or as soon as practicable
thereafter.
Very
truly yours,
/s/ Laura
C. Plumley
Laura C.
Plumley
General
Counsel and Secretary
NEW
COVENANT FUNDS DISTRIBUTOR, INC.