SecProbe.io

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                 The Guardian Life Insurance Company of America
                                7 Hanover Square
                               New York, NY 10004

September 30, 2005

VIA EDGAR

Mr. Christian Sandoe
Division of Investment Management
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, DC  20549-0505

Re:   Preliminary Proxy Materials
      The Park Avenue Portfolio (File Nos. 33-23966; 811-5641)
      The Guardian Variable Contract Funds, Inc. (File Nos. 2-81149; 811-3636)
      GIAC Funds, Inc. (File Nos. 33-37883; 811-6231)
      The Guardian Bond Fund, Inc. (File Nos. 2-81150; 811-3634
      The Guardian Cash Fund, Inc. (File Nos. 2-74905; 811-3324)

Dear Mr. Sandoe:

      This letter is in response the comments you relayed to me in our telephone
conversation of September 16, 2005, with respect to preliminary proxy materials
filed on behalf of the above referenced registrants on September 9, 2005. Each
registrant and applicable series fund is referred to herein as a "Fund." This
letter sets forth each comment and our response.

Proposal 1 - Election of Trustees

      1.    Comment: Please state (if accurate) that Messrs. Ferrara and Futia
            are retired. In addition, please include more detailed information
            regarding Ms. Goggin's employment history after August 2004 and
            describe the nature of Mr. Paggioli's consulting work.

            Response: Agreed. The applicable disclosure has been revised in
            response to this comment.

      2.    Comment: Please state how often the Board meets and state whether
            during the last fiscal year any Trustee attended fewer than 75% of
            the meetings of the Board or Board committees on which the Trustee
            served.

            Response: Agreed. The applicable disclosure has been revised as
            follows:

                "The Board of Trustees meets at least quarterly to review each
                Fund's investments, performance, expenses and other business
                affairs. During the last fiscal year, no Trustee attended fewer
                than 75% of the meetings of the Board or the Board Committees on
                which the Trustee served."

      3.    Comment: In the Compensation Table, where it is stated that the
            Interested Trustees are not compensated by the Funds, please include
            such information in the table itself rather than in a narrative
            format, showing the dollar amounts received as $0.
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            Response: Agreed. The applicable disclosure has been revised
            in response to this comment.

      4.    Comment: In the section entitled "Recommended Shareholder Action and
            Required Vote," for The Guardian Variable Contract Funds, Inc., The
            Guardian Bond Fund, Inc., The Guardian Cash Fund, Inc. and GIAC
            Funds, Inc., please add disclosure that explains the voting
            requirements for the election of Directors in plain English.

            Response: Agreed. The applicable disclosure has been revised in
            response to this comment as follows:

                  "The nominees for Directors of The Guardian Variable Contract
                  Funds, Inc., The Guardian Bond Fund, Inc. and The Guardian
                  Cash Fund, Inc. will be elected by the affirmative vote of the
                  holders of a majority of the outstanding shares entitled to
                  vote, which means if more than 50% of the Fund's outstanding
                  shares are voted in favor of election. The nominees for
                  Directors of GIAC Funds, Inc. will be elected by the
                  affirmative vote of a majority of the outstanding shares
                  entitled to vote present in person or represented by proxy,
                  which means if more than 50% of the Fund's shares that are
                  represented at the meeting are voted in favor of election."

Proposal 2 - Changes to Fundamental Investment Policies

      1.    Comment: Throughout Proposal 2, please indicate whether an Affected
            Fund may operate differently if proposals 2(a) through 2(t) are
            approved, if the Affected Fund cannot so operate currently.

            Response: Agreed. The applicable disclosure has been revised or
            supplemented as appropriate in response to this comment. For
            example, see Proposal 2(e) (real estate) and Proposal 2(q)
            (options).

      2.    Comment: In Proposal 2(c), please discuss the risks of investments
            in short sales, futures and reverse repurchase agreements.

            Response: Agreed. The following disclosure has been added in
            response to this comment:

                  "A Fund's use of short sales involves certain risks, including
                  potential loss if the market price of the security sold short
                  increases between the date when the Fund enters into the short
                  position and the date when the Fund closes the short position.
                  A Fund's use of call options and put options similarly
                  involves risks. The purchaser of a call option acquires the
                  right to buy a security at a fixed price during a specified
                  period. The writer (seller) of such an option is the obligated
                  to sell the security if the option is exercised, and bears the
                  risk that the security's market price will increase over the
                  purchase price set by the option. The purchaser of a put
                  option acquires the right to sell a security at a fixed price
                  during a specified period. The writer of such an option is
                  then obligated to buy the security if the option is exercised,
                  and bears the risk that the security's market price will
                  decline from the purchase price set by the option. The risks
                  associated with purchasing and writing put and call

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                  options on financial futures contracts can be influenced by
                  the market for financial futures contracts. An increase in the
                  market value of a financial futures contract on which the Fund
                  has written an option may cause the option to be exercised. In
                  this situation, the benefit to the Fund would be limited to
                  the value of the exercise price of the option and, if a Fund
                  closes out the option, the cost of entering into the
                  offsetting transaction could exceed the premium the Fund
                  initially received for writing the option. In a reverse
                  repurchase agreement transaction, a Fund sells securities to a
                  bank or securities dealer and agrees to repurchase them at an
                  agreed time and price. Reverse repurchase agreements involve
                  the risk that the buyer of the sold securities might be unable
                  to deliver them when a Fund seeks to repurchase the
                  securities."

      3.    Comment: In Proposal 2(e), please list the Affected Funds that may
            not currently invest in real estate investment trusts.

            Response: Agreed. The applicable disclosure has been revised as
            follows:

                  "If shareholders approve the proposal, each of the Affected
                  Funds would be permitted to invest in the securities described
                  in the proposed amendment. Currently, The Guardian Park Avenue
                  Fund and The Guardian Asset Allocation Fund may not invest in
                  real estate investment trusts. If shareholders approve the
                  proposal, each Fund would be permitted to invest in real
                  estate investment trusts consistent with its investment
                  objective."

      4.    Comment: In Proposal 2(i), please discuss whether any Affected Fund
            would operate differently under the non-fundamental restriction with
            respect to illiquid securities as compared to the restriction being
            repealed.

            Response: No Affected Fund is expected to operate differently than
            it currently does with respect to investments in illiquid securities
            under the non-fundamental restriction.

      5.    Comment: In Proposal 2(r), describe any risks associated with
            investments in warrants.

            Response: Agreed. The applicable disclosure has been revised in
            response to this comment as follows:

                  "Warrants are normally issued together with a bond or
                  preferred stock, and permit the buyer to purchase an
                  underlying asset (typically common stock) of the issuer at a
                  specified price. Warrants are subject to volatility risk of
                  derivatives generally, because the value of the warrant is
                  based on the value of the underlying asset, and the value of
                  the warrant may rise or fall more rapidly than the change in
                  value of the underlying asset. Warrant holders do not have the
                  voting rights of common stockholders."

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      6.    Comment: In Proposal 2(t), please revise the proposed fundamental
            investment restriction to include the words "tax-exempt" in the
            policy to invest at least 80% of The Guardian Tax-Exempt Fund's net
            assets in municipal obligations.

            Response: Agreed. The proposed fundamental investment policy for The
            Guardian Tax-Exempt Fund has been revised in response to this
            comment.

Proposal 4

      1.    Comment: In Proposal 4, please discuss what changes the Trustees
            could make to the trust document that previously required
            shareholder approval.

            Response: If Proposal 4 is approved, the Trustees would be
            authorized to make any changes to the trust document that are not
            expressly required to be approved by shareholders. For example, as
            discussed in Proposal 3, the Trustees would be authorized to
            increase or decrease the maximum number of members that may serve on
            the Board in order to comply with new regulatory requirements,
            without obtaining shareholder approval. Shareholders would continue
            to have the express right to approve changes in their voting rights,
            changes to the amendment provisions of the trust document, and any
            matter required by applicable law to have shareholder approval. In
            addition, the Trustees may request shareholder approval of matters
            for which shareholder approval is not expressly required by the
            trust document. After our consultation with Massachusetts counsel,
            we believe that the proposed language with respect to this proposal
            is necessary to preserve the ability of the Trustees to submit
            proposals to shareholders on matters that do not expressly require
            shareholder approval.

Other Matters

      1.    Comment: State how the costs of preparation of the proxy materials
            will be allocated among the Funds.

            Response: Each Fund will bear its pro rata share of such costs. The
            applicable disclosure has been revised in response to this comment.

      2.    Comment: Please use bold type for the disclosure regarding how
            shareholders may obtain copies of the Funds' shareholder reports,
            and include such disclosure in the first two pages of the proxy
            statement.

            Response: Agreed. The requested disclosure has been added in bold
            type to the second page of the proxy statement, as follows:

                  "SHAREHOLDERS MAY REQUEST A FREE COPY OF THE FUNDS' MOST
                  RECENT ANNUAL AND SEMI-ANNUAL REPORTS BY CALLING
                  1-800-221-3253 OR BY WRITING GUARDIAN INVESTOR SERVICES LLC, 7
                  HANOVER SQUARE, NEW YORK, NEW YORK 10004."

      3.    Comment: Please state how many votes may be cast per share owned.

            Response: Agreed. Disclosure that each share is entitled to one vote
            was included in the Notice of the Special Meeting and has also been
            added to the proxy statement in response to this comment.

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Representations

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

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      Please do not hesitate to contact me at (212) 598-1297 if you have further
questions or comments, or if you require further information.

Sincerely,

Kathleen M. Moynihan
Assistant Counsel

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