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								  ROPES & GRAY LLP

          191 NORTH WACKER DRIVE
3ND FLOOR

          CHICAGO, ILLINOIS 60606-4302
WWW.ROPESGRAY.COM

  Rita Rubin

  Ropes & Gray LLP

  191 North Wacker Drive 32nd Floor

  Chicago, IL 60606-4302

  T +1 312 845 1241

  rita.rubin@ropesgray.com

October 19, 2021

via edgar

Matthew S. Williams

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, DC 20549

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

(File Nos. 811-03313 and 333-259405)

Dear Mr. Williams:

Below are responses to your comments, which
we received from you via telephone on October 5, 2021, with regard to the Registrant’s proxy and registration statement on Form
N-14 (together, the “Registration Statement”) relating to: (i) the proposed investment advisory agreement for Government Select
Series, a series of PFM Funds (the “Acquired Fund”); and (ii) the proposed reorganization of the Acquired Fund into Government
Obligations Fund, a series of the Registrant (the “Acquiring Fund”). The Registration Statement was filed with the U.S. Securities
and Exchange Commission (the “Commission”) on September 9, 2021. At the Staff’s request, the Registrant subsequently
filed a delaying amendment with respect to the Registration Statement on October 6, 2021, pursuant to Rule 473 under the Securities Act
of 1933, as amended.

A summary of the Staff’s comments, along
with the Registrant’s responses, is set forth below. Undefined capitalized terms used herein have the same meaning as in the Registration
Statement.

General Comments

 1. Comment: Where a comment is made with respect to disclosure in one location, it may be applicable
to other places in the Registration Statement.

Response: The Registrant acknowledges
that where a comment is made with respect to disclosure in one location that it may be applicable to other locations in the Registration
Statement and confirms that any such changes will be made in all applicable locations in the Registration Statement.

 2. Comment: Confirm herein that the Meeting will be held in accordance with applicable Commission
guidance, as well as applicable state and federal law.

Response: The Registrant so
confirms.

 3. Comment: Please address in the Registration Statement whether the Change in Control will raise
implications under Section 15(f) of the Investment Company Act of 1940, as amended (the “1940 Act”).

Response:
The Registrant has added a section to the Registration Statement under “ADDITIONAL INFORMATION
ABOUT THE REORGANIZATION” titled “Section 15(f) of the 1940 Act,” which states:

Section 15(f) of the 1940 Act provides
a non-exclusive “safe harbor” under which an investment adviser to a registered investment company or an affiliated person
of such an investment adviser may receive any amount or benefit in connection with a sale of securities or any other interest in such
adviser which results in an assignment of an investment advisory contract with such company if (i) for a period of three years following
such assignment, a majority of the board of directors of such company are not interested persons of the investment adviser of such company
or the predecessor adviser of such company and (ii) no “unfair burden” is imposed on such company as a result of such assignment
or any express or implied terms, conditions or understandings applicable thereto. USBAM has agreed not to, and has agreed not to cause
its affiliates to, take (or fail to take) any action if such action (or failure to take such action) would have the effect, directly and
indirectly, of causing the requirements of any of the provisions of Section 15(f) of the 1940 Act not to be met in respect of the Plan
of Reorganization as to the Acquiring Fund.

 4. Comment: As it relates to the Advisory Agreement Proposal, please describe briefly and state
the approximate amount of, where practicable, any material interest, direct or indirect, of any trustee of the Acquired Fund in any material
transactions since the beginning of the most recently completed fiscal year, or in any material proposed transactions, to which PFMAM,
any parent or subsidiary of PFMAM, or any subsidiary of the parent of such entities was or is to be a party.

Response: The Registrant supplementally
confirms that, as it relates to the Advisory Agreement Proposal, none of the independent trustees of the Acquired Fund held any material
direct or indirect interest in any material transactions since the beginning of the most recently completed fiscal year to which PFMAM,
any parent or subsidiary of PFMAM, or any subsidiary of the parent of such entities was or is to be a party. Upon the completion of USBAM’s
pending acquisition of PFMAM, the Acquired Fund’s interested trustee will begin to operate under the terms of a one-year consulting
agreement with USBAM and will receive payment for such consulting services.

    2

Shareholder Letter

 5. Comment: Consider making bold the following sentence on page i of the shareholder letter:
“As there will be no in-person voting at the virtual Meeting, we strongly urge you to submit your votes by proxy in advance of the
Meeting by mail or by email to pfmfunds@pfm.com.”

Response: The requested change
has been made.

 6. Comment: Provide disclosure that clarifies the role of PFM Asset Management, LLC (“PFMAM”)
and its portfolio managers with respect to the Acquiring Fund upon completion of the Reorganization and the Change in Control.

Response: The Registrant has
added the following disclosure:

Although PFMAM will become a wholly-owned
subsidiary of USBAM, the portfolio managers of the Acquired Fund will not continue in such capacity with respect to the Acquiring Fund
following the Reorganization; USBAM and the Acquiring Fund’s current portfolio managers will continue to manage the Acquiring
Fund following the Reorganization.

 7. Comment: On page i, where the shareholder letter states that each of the Acquired Fund and
Acquiring Fund is a “‘government money market fund’ (as that term is defined in Rule 2a-7 under the Investment Company
Act of 1940, as amended (‘1940 Act’)) and, as such, invests 99.5% or more of its total assets in cash, government securities,
and/or repurchase agreements that are collateralized fully,” revise the phrase “collateralized fully” to read
“collateralized solely by government securities or cash,” if applicable.

Response: The Registrant has
revised the phrase “collateralized fully” to read “collateralized solely by U.S. government securities,” where
applicable.

 8. Comment: On page ii, where the shareholder letter states that, “in accordance with the
Plan of Reorganization (the ‘Closing Date’), you will receive Class Z shares of the Acquiring Fund in an amount equal to the
dollar value of your interest in the Acquired Fund on the Closing Date,” revise the phrase “dollar value” to
read “aggregate net asset value.”

Response: The requested change
has been made.

    3

Notice to Shareholders

 9. Comment: Please position disclosure relating to the parties that will be covering the costs
associated with the Advisory Agreement Proposal and the Reorganization Proposal near the beginning of the “Q&A” section.

Response: The requested change
has been made.

 10. Comment: Please position near the beginning of the “Q&A” section disclosure
noting that the New Advisory Agreement is only intended to serve as a bridge during the period of time between the Change in Control and
the Reorganization where the Change in Control occurs prior to the Reorganization.

Response: The requested change
has been made.

 11. Comment: On page ii, under “Will the portfolio management of the PFM Fund change?”,
clarify that the Acquired Fund will be subject to the supervision of the PFM Board between the Change in Control and the Reorganization
where the Change in Control occurs prior to the Reorganization.

Response: The Registrant has
added the following disclosure:

The PFM Fund will also continue to
be subject to the supervision of the PFM Board until the completion of the Reorganization.

 12. Comment: On page iv, under “How will the Reorganization impact fees and expenses?”,
please clarify that, beginning on November 1, 2022, the Acquiring Fund’s fees and expenses may increase after the sentence that
reads: “USBAM has contractually agreed to waive fees and reimburse other fund expenses through October 31, 2022, so that
total annual fund operating expenses, after waivers, do not exceed 0.18%.”

Response: The Registrant notes
that the disclosure accurately describes the terms of the current expense limitation agreement and is compliant with the disclosure requirements
of Items 3 and 19 of Form N-1A (as incorporated into Items 3 and 12 of Form N-14, respectively). In view of the fact that the Board of
the Registrant has made no determinations with respect to any future expense limitation agreements, and given that the current disclosure meets the applicable form requirements
of both Form N-1A and Form N-14, the Registrant respectfully declines to make the requested change.

 13. Comment: Please position the question, “What are the potential outcomes with respect
to my votes on the Advisory Agreement Proposal and the Reorganization Proposal?”, and the accompanying response on page vi near
the beginning of the “Q&A” section.

Response: The requested change
has been made.

    4

Proxy Statement/Prospectus

 14. Comment: On page 2, with respect to the disclosure that reads, “since the Acquired Fund’s
current portfolio composition is substantially identical to that of the Acquiring Fund, it is not currently expected that any significant
portfolio sales will occur solely in connection with the Reorganization (such sales are expected to be less than 5% of the assets of
the Acquired Fund),” please revise the parenthetical to be consistent with the disclosure on page 7 that reads, “PFMAM
will align or sell approximately 0% of the PFM Fund’s holdings and invest the proceeds in securities that the FAF Fund wishes to
hold.”

Response: The subject parenthetical
has been revised to read, “(such sales are expected to be less than 5% account for less than 1% of
the Acquired Fund’s assets of the Acquired Fund).”

 15. Comment: Please revise the statement on page 2 that reads, “The Board recommends that
you vote ‘FOR’ the following Proposals,” to state, “The Board recommends that you vote ‘FOR’ each
of the Advisory Agreement Proposal and the Reorganization Proposal.”

Response: The requested change
has been made.

 16. Comment: On page 3, under “Overview of the New Advisory Agreement,” please replace
the sentence that reads, “The following description of the material terms of the New Advisory Agreement is only a summary and is
qualified in its entirety by reference to Appendix C,” with the following: “The following description of the material terms
of the New Advisory Agreement is only a summary. For the complete terms of the New Advisory Agreement, please refer to Appendix C.”

Response: The requested change
has been made.

 17. Comment: On page 4, under “Principal Executive Officers and Directors,”
please clarify that, upon completion of the Reorganization, the advisory agreement in effect with respect to the Acquired Fund will terminate,
and the Acquiring Fund’s investment adviser will continue to manage the Acquiring Fund.

Response: The following disclosure
had been added:

If the New Advisory Agreement becomes
effective prior to the Reorganization, the New Advisory Agreement will terminate upon completion of the Reorganization and USBAM will
continue to serve as the Acquiring Fund’s investment adviser after the Reorganization.

 18. Comment: On page 5, under “Benefits to PFMAM” in the section titled “Board
Considerations,” the Registrant states, “The Independent Board Member determined that neither PFMAM nor USBAM, as PFMAM’s
parent company, would receive any significant indirect benefits from their respective relationship with the PFM Trust or the PFM
Fund, and that PFMAM would receive any ‘float’ benefit in connection with transfers of funds in connection with the
purchase or redemption of shares of the PFM Fund.”

    5

Please: (i) make the reference to the
“Independent Board Member” plural; (ii) revise the paragraph to include discussion of whether the Independent Board Members
considered whether PFMAM or USBAM, as PFMAM’s parent company, would receive any significant direct benefits from their respective
relationship with the PFM Trust or the PFM Fund; and (iii) clarify the meaning of the term “float benefit.”

Response: The requested change
has been made.

 19. Comment: On page 5, under “Economies of Scale” in the section titled “Board
Considerations,” the Registrant states, “The Independent Board Members further considered the additional economies of scale
that were expected to be realized by PFMAM as a result of its acquisition by USBAM…” Please clarify the relevance of this
analysis in light of the contemplated Reorganization.

Response: The subject disclosure
has been revised to read, “The Independent Board Members further considered the additional economies of scale that were expected
to be realized by PFMAM as a result of its acquisition by USBAM, including the potential to allocate relatively fixed operating
and administrative expenses across a broader asset base, and the extent to which these economies of scale would be shared with
the PFM Fund and its shareholders, including through potentially reduced administrative expenses borne by the PFM Fund.”

 20. Comment: On page 6, under “Principal Investment Strategies,” please state that
the Acquiring Fund will provide shareholders with at least 60 days advance notice before changing its policy to invest exclusively in
short-term U.S. government securities, including repurchase agreements secured by U.S. government securities.

Response: The requested disclosure
has been added.

 21. Comment: On page 7, under “Operating Expenses,” please state that, at the end
of the term of the expense limitation agreement currently in effect with respect to the Acquiring Fund (i.e., beginning on November
1, 2022), the Acquiring Fund’s fees and expenses may increase.

Response: The Registrant notes
that the disclosure accurately describes the terms of the current expense limitation agreement and is compliant with the disclosure requirements
of Items 3 and 19 of Form N-1A (as incorporated into Items 3 and 12 of Form N-14, respectively). In view of the fact that the Board of
the Registrant has made no determinations with respect to any future expense limitation agreements, and given that the current disclosure
meets the applicable form requirements of both Form N-1A and Form N-14, the Registrant respectfully declines to make the requested change.

 22. Comment: Under “Comparative Fee and Expense Tables,” beginning on page 8, please
ensure all figures provided with respect to the Acquired Fund’s and Acquiring Fund’s fees and expense are current.

Response: The Registrant so
confirms.

    6

 23. Comment: On page 9, in the first footnote below the “Annual Fund Operating Expenses”
table, please clarify whether USBAM will be able to recoup reduced fees under the terms of the fee deferral agreement between the Acquired
Fund and PFMAM after the Reorganization. If USBAM is able to recoup such reduced fees, provide the basis for such arrangement.

Response: The following disclosure
has been added to the subject footnote:

USBAM will not be able to recoup any
previously deferred fees that remain outstanding under the terms of the fee deferral agreement between the PFM Trust and PFMAM after the
Reorganization.

 24. Comment: On page 9, under “Expense Examples,”
please revise the bullet that states, “You redeem your investment at the end of each time period,” to read, “You hold
or redeem your investment at the end of each time period.”

Response: The requested change
has been made.

 25. Com