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


October 28, 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)(1) of the
Securities Act of 1933, as amended (the "1933 Act"), and Section 8(b) of the
Investment Company Act of 1940, Post-Effective Amendment No. 21 to the
Registration Statement on Form N-1A ("Post-Effective Amendment No. 21") of
Schroder Series Trust (the "Trust"). This filing contains no changes to the
prospectuses or statement of additional information contained in Post-Effective
Amendment No. 20 to the Registration Statement on Form N-1A of the Trust
("Post-Effective Amendment No. 20") other than to add "red herring" language and
related disclosures.

         This filing is intended to become effective on December 27, 2004, the
same date on which Post-Effective Amendment No. 20, that was filed on October
13, 2004 under Rule 485(a)(2), would become effective. We have discussed the
proposed effective date for Post-Effective Amendment No. 21 with the staff of
the Division of Investment Management and they confirmed that they had no
objection to the Trust's filing Post-Effective Amendment No. 21 under Rule
485(a)(1) to become effective on December 27, 2004 notwithstanding the prior
filing of Post-Effective Amendment No. 20 under Rule 485(a)(2) which was to
become effective on the same day.

         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.