SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>sec_response-1130.txt
<DESCRIPTION>RESPONSE TO SEC COMMENTS DATED NOVEMBER 30, 2004
<TEXT>
[USAA       9800 Fredericksburg Road
EAGLE       San Antonio, Texas 78288
LOGO (R)]

November 30, 2004

VIA E-MAIL AND EDGAR

Ms. Kim Browning
Securities and Exchange Commission
Division of  Investment
Management 450 Fifth Street, N.W.
Washington, D.C.  20549-0506

RE:      USAA Mutual Fund, Inc. (the Company or the Funds)
         Post-Effective Amendment No. 70
         1933 Act File No. 2-49560
         1940 Act File No. 811-2429

Dear Ms. Browning:

         This  letter  responds  to the  comments  which you  provided  to me by
telephone on November 18, 2004, which Eileen Smiley and I subsequently discussed
with you and Richard  Pfordte on November 23, 2004, and which I again  discussed
with you and,  for a portion of our call,  Richard  Pfordte on November 29, 2004
regarding the above-referenced filings.

         As a  preliminary  matter  and  as  requested  by  the  Commission,  in
responding  to  your  comments,   the  Company  acknowledges  that:  (i)  it  is
responsible for the adequacy and accuracy of the disclosure in the filings; (ii)
the staff comments or changes to disclosure in response to staff comments in the
filings  reviewed by the staff do not foreclose the  Commission  from taking any
action with  respect to the filing;  and (iii) the Company may not assert  staff
comments  as a defense in any  proceeding  initiated  by the  Commission  or any
person under the federal securities laws of the United States.

         Listed  below  are  your  comments  with  the  Company's   accompanying
responses.  For easier reading,  the Company will be referred to as "we" or "us"
throughout this letter.

UNIVERSAL COMMENTS ON THE PROSPECTUSES

1.       COMMENT:  Remove all references to the adviser and any subadviser(s)
         from Items 1, 2, and 3 of the prospectuses.

         RESPONSE: As we discussed, we believe the inclusion of this information
         in Item 2 of our  prospectuses  is not  inappropriate.  We believe  the
         information is important to our  shareholders and in no way impedes the
         presentation of the primary information called for by Item 2. Given the
         importance  of  the  Company's  "manager-of-managers"   structure,  our
         preference is to leave this disclosure intact.

2.       COMMENT:  With  respect to the  paragraph  at the top of the first page
         defining  USAA  Investment  Management  Company as "we" or "us," ensure
         that  "we" and  "us"  are  correctly  used  throughout  the rest of the
         prospectus.

         RESPONSE:  We reviewed the usages of "we" and "us" in our prospectuses,
         making any appropriate clarifications.

3.       COMMENT: Change the word "main" to "principal" in the headings "What is
         the Fund's  Investment  Objective and Main Strategy?" and "What Are the
         Main Risks of Investing in This Fund?"

         RESPONSE:  The requested changes have been made.
<PAGE>

4.       COMMENT:  Ensure  that all principal strategies and principal risks are
         summarized in Item 2 of the prospectuses.

         RESPONSE:  We added  language  to Item 2 of the  Science  &  Technology
         Fund's  prospectus  stating  that the Fund may  invest up to 50% of its
         assets in foreign  securities.  Also,  for the funds that  reserve  the
         right to invest up to 20% of their  assets in  foreign  securities,  we
         have added disclosure identifying  investments in foreign securities in
         Item 2. With these  changes,  we believe our  prospectuses  satisfy the
         requirements of Item 2.

5.       COMMENT:  In  the  "Fees  and  Expenses"  section,  under  the  heading
         "Shareholder  Transaction  Expenses  - Direct  Costs,"  change the word
         "may" to "will" in the sentence that states: "In addition,  if you sell
         or exchange  shares of the Fund within five  business days of purchase,
         you may be subject to a  short-term  trading fee payable to the Fund of
         up to 2% of the value of the shares redeemed or exchanged."

         RESPONSE: As we discussed, we currently are not charging this fee for a
         variety of reasons,  but, if we decide to begin  charging  this fee, we
         will inform shareholders of this in a prospectus supplement.

6.       COMMENT:  Reformat the fee table to match the vertical format set forth
         in Item 3.

         RESPONSE:  As we discussed,  we believe our horizontal  presentation of
         the fee table satisfies the  requirements of Item 3, and,  accordingly,
         believe no changes are necessary.

7.       COMMENT:  For any Funds with a fee waiver,  represent  that the adviser
         has no right to later  recapture  waived  amounts,  or  disclose in the
         prospectus that the adviser has such right.

         RESPONSE:  The Funds with fee waivers have no right to later  recapture
         waived amounts.  Some Funds once had such rights, but these rights have
         since expired.

8.       COMMENT:  For any  Fund  with a fee  waiver  disclosed  in a table in a
         footnote to the fee table,  ensure that the footnote is less  prominent
         than the fee table.

         RESPONSE:  As we  discussed,  the table in the fee waiver  footnote  is
         presented in a smaller  font than the fee table and is  therefore  less
         prominent.

9.       COMMENT:  In Item 4 of the  prospectuses,  ensure  that  all  principal
         strategies  and related  risks are included and that any  non-principal
         strategies  or risks are  distinguishable  from and do not  impede  the
         presentation of the principal strategies and risks.

         RESPONSE: As we discussed, we believe that our prospectuses include the
         information  called  for by Item 4 and  that any  information  included
         about  non-principal  strategies and risks is distinguishable  from and
         does not impede the presentation of the principal strategies and risks.

10.      COMMENT:  Appendix  A should be  referred  to as a  section  containing
         additional  information  about a Fund,  rather than being labeled as an
         appendix.

         RESPONSE:  The  requested  change has been made.  The  Appendix  is now
         referred  to as  "Additional  Information  About the Fund's  Investment
         Policies."

11.      COMMENT:  In the "How to Invest"  section, in the first paragraph under
         the heading "Effective Date," define "proper form."

         RESPONSE: The requested change has been made. The sentence now reads as
         follows:  "When you make a purchase,  your purchase will be the NAV per
         share next determined after we receive your request in proper
<PAGE>

         form  (e.g.,  complete,  signed  application  and  payment)."  We note,
         however,  that a quick  review of other  major fund group  prospectuses
         indicates the use of the term "proper form" without further explanation
         is not uncommon.

12.      COMMENT:  In the "How to Invest" section, in the second paragraph under
         the heading  "Effective  Date," change all  references to the Servicing
         Agent "accepting" orders to "receiving" orders.

         RESPONSE:  The requested changes have been made.

13.      COMMENT:  In the "How to Invest" section, in the second paragraph under
         the  heading  "Effective  Date,"  make the  last  sentence  a  separate
         paragraph  and make it clear  that an order will  receive  the NAV next
         calculated after the Fund receives the order.

         RESPONSE:  The requested changes have been made. The sentence now reads
         as follows:  "The Fund or the Fund's transfer agent also may enter into
         agreements  whereby  orders may be executed at the NAV next  calculated
         after  receipt  of the order by the Fund,  with  payment  for the order
         being made on the next business day."

14.      COMMENT:  In  the  "How  to  Redeem"  section,  describe  the  "limited
         circumstances"  mentioned in the sentence which states "[i]n  addition,
         the Fund may elect to suspend the  redemption of shares or postpone the
         date of payment in limited circumstances."

         RESPONSE: The requested change has been made. The sentence now reads as
         follows: "In addition,  the Fund may elect to suspend the redemption of
         shares or postpone the date of payment in limited  circumstances (e.g.,
         if the NYSE is closed or when permitted by order of the SEC)."

15.      COMMENT:   In   the   "Shareholder   Information"   section,   in   the
         second-to-last  paragraph under the heading  "Valuation of Securities,"
         disclose that the adviser is the entity that will fair value securities
         in good faith using valuation  procedures  approved by the Fund's Board
         of Directors.

         RESPONSE:  The requested  change has been made. This sentence now reads
         as follows:  "Securities  for which market  quotations  are not readily
         available  or are  considered  unreliable,  or whose  values  have been
         materially  affected  by  events  occurring  after  the  close of their
         primary  markets but before the pricing of the Fund, are valued in good
         faith by us at fair value using  valuation  procedures  approved by the
         Fund's Board of Directors."

16.      COMMENT:  If a  Fund will  engage in  frequent  and active trading as a
         principal strategy, disclose this in Item 2 of the prospectus.

         RESPONSE:  None of the Funds  intend to engage in  frequent  and active
         trading as a principal  strategy.  While  certain of the Funds have had
         portfolio  turnover rates exceeding 100%,  those rates, as set forth in
         our  SAI,  were  due  to  subadviser  changes  which  resulted  in  the
         repositioning  of the applicable  Funds'  portfolios.  In Item 4 of the
         prospectuses  for each  subadvised  fund,  we have added the  following
         disclosure in the Management Risk section that identifies and describes
         the risks arising from a change in the subadvisers:

                  In  addition,   we  operate  under  a  "manager  of  managers"
                  structure which gives us the right, with the prior approval of
                  the Fund's Board of Directors,  to change  subadvisers.  If we
                  replace a subadviser  of the Fund,  the Fund could  experience
                  higher portfolio  turnover and higher  transaction  costs than
                  normal if the new subadviser realigns the portfolio to reflect
                  its investment techniques and philosophy. A realignment of the
                  Fund's  portfolio  could  result in higher  capital  gains and
                  distributions,   which   could   negatively   affect  the  tax
                  efficiency of the Fund for that fiscal year.
<PAGE>

         Because changing  subadvisers is not a principal investment strategy of
         any  fund,  we have not  included  this  disclosure  in Item 2 but have
         included it as additional  risk disclosure in Item 4. We do not believe
         that  this  additional  risk  disclosure   impedes  the  required  risk
         disclosure.

17.      COMMENT:  For any Fund with an 80% investment policy, disclose that
         "assets" includes "any borrowings for investment purposes."

         RESPONSE:  While we do not  necessarily  agree  that Rule 35d-1 or Form
         N-1A require any such disclosure,  we nevertheless  will add disclosure
         to the paragraph in our SAI that  discusses  each Fund's 80% investment
         policy.  The added  disclosure  will read as follows:  "For purposes of
         these 80%  investment  policies,  `assets'  means net assets,  plus the
         amount of any borrowings for investment purposes."

18.      COMMENT:  For any Fund with an 80% investment  policy,  disclose in the
         prospectus that the policy is fundamental or,  alternatively,  that the
         Fund may change the policy by providing  shareholders  with at least 60
         days prior notice of any change to the policy.

         RESPONSE:  We do not believe  that Rule 35d-1 or Form N-1A  require any
         such  disclosure in the  prospectus or SAI. We,  nevertheless,  already
         include  disclosure  in our SAI regarding the policy to provide 60 days
         prior notice to  shareholders  in the event of a change to a Fund's 80%
         policy.

COMMENT SPECIFIC TO THE PROSPECTUS FOR THE SCIENCE & TECHNOLOGY FUND

19.      COMMENT:  In the "Fund  Investments"  section,  in the first  paragraph
         under the heading "What is the Fund's principal investment  strategy?",
         delete the word  "generally" from the sentence which states "[t]he term
         `equity  securities'  is  generally  used  to  include  common  stocks,
         preferred  stocks,  securities  convertible  into  common  stocks,  and
         securities that carry the right to buy common stocks."

         RESPONSE:  The requested  change has been made. This sentence now reads
         as follows:  "The  `equity  securities'  in which the Fund  principally
         invests are common stocks,  preferred  stocks,  securities  convertible
         into common stocks,  and securities  that carry the right to buy common
         stocks."

COMMENTS SPECIFIC TO THE PROSPECTUS FOR THE SMALL CAP GROWTH FUND

20.      COMMENT:  In the "Fund  Investments"  section,  under the heading "What
         defines small-cap stocks?", disclose that this is how this Fund defines
         small-cap.  In other words,  make it clear that this is not a universal
         definition of "small-cap stocks."

         RESPONSE:  The requested  change has been made.  The first  sentence of
         this section now begins as follows:  "The Fund defines small-cap stocks
         as those of companies that have a market capitalization...."

21.      COMMENT:  In the "Fund  Investments"  section,  under the heading "What
         defines   small-cap   stocks?",    disclose   the   range   of   market
         capitalizations  for each  index and also state how often each index is
         re-constituted.

         RESPONSE:  The  requested  changes have been made.  Beginning  with the
         second sentence, this section now states as follows:

              As of September 30, 2004, the largest market  capitalization stock
              in the S&P SmallCap 600 Index was  approximately  $3.5 billion and
              the smallest  capitalization  stock was approximately $40 million.
              As of October 31, 2004, the largest market capitalization stock in
              the  Russell  2000 Index was  approximately  $2.9  billion and the
              smallest  capitalization stock was approximately $49 million. Keep
              in mind that the market  capitalization of the companies listed in
              each   exchange  may  change  with  market   conditions   and  the
              composition  of either  index.  Standard & Poor's makes changes to
              the
<PAGE>

              S&P SmallCap 600 Index when needed, whereas the Russell 2000 Index
              is  reconstituted  on an annual basis (with certain  additions and
              deletions made in between reconstitutions).

COMMENTS ON THE SAI

22.      COMMENT: In the "Investment  Policies" section,  change the word "main"
         to "principal" in the reference to the prospectus  heading "What is the
         Fund's Investment Objective and Main Strategy?".

         RESPONSE:  The requested change has been made.

23.      COMMENT:   In  the  "Investment