Daniel A. Peterson

Attorney

190 Carondelet Plaza, Suite 600

St. Louis, MO 63105

314.345.6246

fax: 314.480.1505

dan.peterson@huschblackwell.com

April 1, 2010

VIA EDGAR

Securities and Exchange Commission

100 F Street, NE

Washington, D.C.  20549-4720

Attention: Patricia P. Williams

Re: First Focus Funds, Inc. (the “Registrant”)

File Numbers 811-08846 and 333-85982

Dear Ms. Williams:

On March 31, 2010, the Registrant filed a preliminary proxy statement (the “Preliminary Proxy”) pursuant to Section 14(a) of the Securities Exchange Act of 1934, as amended.  This letter is being submitted on behalf of the Registrant in order to identify the undersigned, Daniel A. Peterson, of Husch Blackwell Sanders LLP, the Registrant’s outside counsel, as the appropriate party to receive comments from the Securities and Exchange Commission staff (the “Staff”) in connection with such Preliminary Proxy.

Given that, as stated in the Preliminary Proxy, the Registrant proposes to schedule its shareholder meeting on April 30, 2010, and in order to comply with the Registrant’s organizational documents, the Registrant anticipates mailing its final proxy statement on April 16, 2010.  As such, we respectfully request that you contact the undersigned at your earliest convenience to convey the Staff’s comments in order for the Registrant to respond to such comments in a timely manner such that it can continue to meet all appropriate deadlines.

I appreciate your support and cooperation in this matter.  Please do not hesitate to contact me with any questions or concerns at (314) 345-6246.

Sincerely,

/s/ Daniel A. Peterson

Daniel A. Peterson

DAP

cc: Ms. Brittany Fahrenkrog

First National Bank

1620 Dodge Street, Stop 1072

Omaha, Nebraska 68197

Ms. Toni Bugni

Jackson Fund Services

225 West Wacker Drive, Suite 1200

Chicago, Illinois 60606