SecProbe.io

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                  The Guardian Investor Services LLC
                          7 Hanover Square
                     New York, New York 10004-2616

                                      Frank L. Pepe
                                      Senior Vice President and Controller

May 10, 2005

VIA EDGAR

Jason Fox
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, DC  20549-0505

Re:	The Guardian Variable Contract Funds, Inc. (File Nos. 2-
81149 and 811-3636); GIAC Funds, Inc. (File Nos. 33-37883 and 811-
6231); The Guardian Bond Fund, Inc. (File Nos. 2-81150 and 811-3634);
and The Guardian Cash Fund, Inc. (File Nos. 2-74905 and 811-3324)
(the "Funds")

Dear Mr. Fox:

	This letter is in response to the comments you relayed to me in our
telephone conversation on April 11, 2005, with respect to your review of
the annual reports of the Funds as of December 31, 2004 filed with the
Commission on Form N-CSR.  This letter sets forth each comment and
our response.

The Guardian VC Asset Allocation Fund (GVCAAF)
----------------------------------------------

1.	Comment:  In the discussion under the heading "An Update from
Fund Management," the fourth paragraph states "Our investing
was guided by our quantitative model which, as of year-end, has
us invested fully 100% in stocks, 0% in bonds and 0% in cash."
Also, the pie chart shows a breakdown for Cash of 1.21%, but the
Schedule of Investments (SOI) shows repurchase agreements of
33.1%.  Please explain why there is a discrepancy.

Response:  Pursuant to its investment strategy, one of the ways
GVCAAF allocates its assets is by purchasing and selling index
futures (typically S&P 500 Index futures) as a cash equitization
tool.

In a futures contract, there is no actual cash outlay. The cash that
would have been used to purchase the underlying stocks is
invested in a guaranteed short-term investment vehicle (in this
case a repurchase agreement). The futures contract then causes
daily cash flows based upon the change in the underlying index.
Effectively, the cash is converted into equity exposure (to the
underlying index) without the cash actually being spent.

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The pie chart and the report from fund management reflect the
true economic value and allocation of the portfolio. The SOI
corresponds to the custodian bank records and reflects an
accounting treatment that, although accurate from the standpoint
of actual securities held, does not properly reflect how index
futures affect the portfolio from both a return and risk perspective.

We believe it is more meaningful to an investor to show the
economic impact of GVCAAF's investments in index futures rather
than solely to reflect their accounting treatment. The difference in
each presentation is illustrated by considering a portfolio that
consists entirely of S&P 500 index futures:  such a portfolio would
reflect the constitution of the S&P 500 Index, which typically would
show a 100% equity position, with 0% in fixed income and 0% in
cash or cash equivalents.  An accounting treatment of this same
portfolio, however, would show the portfolio as being invested 0%
in equity, 0% in fixed income and 100% in cash.

To explain this apparent discrepancy, we will add appropriate
disclosure.

2.	Comment:  Please explain why GVCAAF invests in futures if it is a
"fund of funds"?  According to Section 12(d)(1)(G) of the
Investment Company Act of 1940, a "fund of funds" is only
allowed to invest in affiliated companies and/or U.S. government
securities.

Response:  GVCAAF is permitted to invest in futures pursuant to
an SEC exemptive order granted on April 1, 1997 (SEC Release
No. IC-22607; File number 812-10282).

Baillie Gifford International Growth Fund (BGIF)
------------------------------------------------

3.	Comment:  Why is the line graph for BGIF in the MDFP section
under the heading "Growth of a Hypothetical $10,000 Investment"
showing a line graph for a period of 15 years rather than the SEC
requirement on Form N-1A of 10 years. We suggest that showing
the return for the 10-year period in the line graph would be better
disclosure for comparability purposes.

Response: In future reports to shareholders, we will show the
ending dollar amount for the 10-year-period as well as the period
since inception.

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Annuity Funds' Schedule of Investments (applies to all the Funds)
-----------------------------------------------------------------

4.	Comment:  For each Fund's footnote disclosure after the SOI, in
      reference to the repurchase agreement's collateral, the AICPA
      Audit Guide requires disclosure of the nature, terms and value of
      the collateral.

Response:  In consultation with our independent accountants, we
believe the disclosure shown in the SOI complies with the
requirements of the Audit Guide.  However, management has
decided to revise and reflect the nature, terms and value of
collateral in the Form N-Q filed for the quarter ended March 31,
2005.

The Guardian VC 500 Index Fund (GVC500IF) and Guardian Bond
-----------------------------------------------------------
Fund (GBF)
----------

5.	Comment: In the Statement of Changes in Net Assets of the
financial section of the shareholder report, please explain why the
total amounts for dividends and distributions to shareholder do not
match the total amount reinvested from dividends and
distributions under the heading "Transactions in Capital Stock" in
the Notes to Financial Statements for the year ended December
31, 2004.

Response:  GVCAAF invests primarily in GVC500IF and GBF as
part of its investment strategy.  GVCAAF has elected to receive
cash rather than shares from any distributions from income and
capital gains from its investment in GVC500IF and GBF.

Representations

       Each Fund acknowledges that SEC staff comments or changes to
the disclosure in the Form N-CSR reviewed by the staff do not foreclose
the Commission from taking any action with respect to the Form N-CSR.
In addition, each Fund acknowledges that it is responsible for the
adequacy and accuracy of the disclosure in the Form N-CSR.  Each Fund
further acknowledges that it 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.

             *         *         *         *          *

       Please do not hesitate to contact me at (212) 598-8445, if you
have further questions or comments, or if you require further information.

Sincerely,

/s/ Frank L. Pepe
-----------------

Frank L. Pepe

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