Subject: File No. S7-19-97
Date:    7/29/97 6:32 PM
     
     
From;      SCM Portfolio Fund, Inc.
           119 Maple Street
           Post Office Box 947
           Carrollton, GA 30117
     
Dear Mr. Katz:
     
     We believe that the Form 24F-2 should continue to require information
about securities registered other than pursuant to rule 24f-2 and that 
shares previously registered other than pursuant to rule 24f-2, sold, and 
then redeemed should be "netted" as allowed under rule 24f-2.  Those of us 
who administer small funds which have registered a relative large number of 
shares in years past may need several years to sell all of those shares and 
those shares should be provided the same benefits as those shares 
registered pursuant to rule 24f-2.  And the Form 24F-2 should address the 
previously registered shares in the calculation process.

     Also, we oppose any requirement for an opinion of counsel during the
annual filing under rule 24f-2. 

     Thank you for consideration of the Commission  of these concerns.
     
                                   Sincerely,
     
     
     
                                   Stephen C. McCutcheon
                                   Chairman of the Board of Directors