Ropes & Gray LLP
                             One International Place
                        Boston, Massachusetts 02110-2624


October 13, 2004


VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549


                 Re:   Schroder Series Trust (File Nos. 333-65632; 811-7840)
                       -----------------------------------------------------


Ladies and Gentlemen:


         We are filing today, through EDGAR, under Rule 485(a)(2) of the
Securities Act of 1933 (the "1933 Act"), and Section 8(b) of the Investment
Company Act of 1940, Post-Effective Amendment No. 20 to the Registration
Statement on Form N-1A of Schroder Series Trust (the "Trust"). The amendment is
being filed to reflect the addition of a new series of the Trust, Schroder
Enhanced Income Fund.

         Please direct any questions concerning this filing to me at (617)
951-7819 or to my colleagues Timothy W. Diggins at (617) 951-7389 and Leigh R.
Fraser at (617) 951-7485. Thank you.


                                            Very truly yours,

                                            /s/ JESSICA O'MARY

                                            Jessica O'Mary


Enclosure

Cc:  Carin F. Muhlbaum, Esq.

     Mr. Alan M. Mandel

     Timothy W. Diggins, Esq.

     Leigh R. Fraser, Esq.