SecProbe.io

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                     Ballard Spahr Andrews & Ingersoll, LLP
                               1735 Market Street
                                   51st Floor
                           Philadelphia, PA 19103-7599
                                 (215) 665-8500

December 27, 2004

Filed Via EDGAR

Mr. Dominic Minore
Examiner
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

         Re:      PBHG Funds PEA 77 (1933 Act) and PEA 75 (1940 Act) to
                  Registration Statement on Form N-1A - File Nos. 2-99810 and
                  811-04391
                  -----------------------------------------------------------

Dear Dominic:

                  Listed below are the responses of PBHG Funds to the comments
you provided on Tuesday, December 7, 2004 regarding the above referenced post
effective amendment to PBHG Funds' registration statement on Form N-1A. The
comments you provided are in bold and PBHG Funds' responses follow in plain
text.

  Comment No.    Comments and Responses

       1         Confirm that the name change of the Dwight Intermediate Fixed
                 Income Fund from the PBHG Intermediate Fixed Income Fund was
                 not made in conjunction with a fund merger.

                 The PBHG Intermediate Fixed Income Fund commenced operations on
                 July 31, 2003 and since that time has been sub-advised by
                 Dwight Asset Management Company. Effective July 28, 2004, the
                 Fund changed its name to the Dwight Intermediate Fixed Income
                 Fund to more prominently feature the Fund's sub-adviser and not
                 in conjunction with a fund merger.

       2         The disclosure in the prospectus and statement of additional
                 information regarding market timing and selective disclosure
                 may need to be more specific to meet the disclosure
                 requirements in the SEC's final rule "Disclosure Regarding
                 Market Timing and Selective Disclosure of Portfolio Holdings"
                 (SEC Rel. No. IC-26418), which effective date is December 5,
                 2004.

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                 The following disclosure will be added to the last page of PBHG
                 Funds' prospectus:

                 "The complete portfolio holdings of each Fund as of the end of
                 each calendar quarter is available on the PBHG Funds website at
                 WWW.PBHGFUNDS.COM. Portfolio holdings will be posted to the
                 website on the 15th calendar day after the end of each calendar
                 quarter and will remain available until replaced with the
                 Fund's portfolio holdings for the following calendar quarter
                 end."

       3         In the statement of additional information, the disclosure in
                 the sixth and seventh paragraphs under the section titled
                 "Portfolio Transactions" does not conform to new Rule 12b-1(h)
                 under the Investment Company Act of 1940, as amended, as
                 adopted in the SEC's final rule "Prohibition on the Use of
                 Brokerage Commissions to Finance Distribution" (SEC Rel. No.
                 IC-16591), which effective date is December 13, 2004. This
                 disclosure will need to be modified.

                 The aforementioned disclosure in PBHG Funds' SAI will be
                 modified as set forth on Exhibit A attached hereto.

       4         The financial statements incorporated by reference in the
                 registration statement are dated more than 245 days prior to
                 the date this post effective amendment is expected to become
                 effective and, pursuant to Rule 3-18(c) of Regulation S-X, will
                 need to be updated.

                 PBHG Funds shall incorporate by reference into its statement
                 of additional information the financial statements dated
                 September 30, 2004 contained in PBHG Funds' 2004 Semi-Annual
                 Report, which was filed with the Commission on December 1,
                 2004.

         With respect to the foregoing comments, PBHG Funds acknowledges the
following:

         1. PBHG Funds is responsible for the adequacy and accuracy of
disclosure in its filings.

         2. 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 filings.

         3. PBHG Funds 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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         With respect to the above responses for which PBHG Funds undertakes to
make changes, such changes will be made in a post effective amendment to be
filed via Rule 485(b) on or about January 14, 2005. Please contact the
undersigned at 215-864-8621 if you wish to discuss any of our responses to your
comments.

         On behalf of PBHG Funds, we appreciate your assistance in connection
with this review.

                                                     Very truly yours,

                                                     /s/ Matthew DiClemente
                                                     ----------------------
                                                     Matthew DiClemente

MRD/mrd
cc:      John M. Zerr
         Vice President and Secretary
         PBHG Funds

         Robert E. Putney, III
         Vice President and Assistant Secretary
         PBHG Funds

         William H. Rheiner, Esq.
         Ballard Spahr Andrews & Ingersoll, LLP

         John N. Ake, Esq.
         Ballard Spahr Andrews & Ingersoll, LLP

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                                    EXHIBIT A

In response to your comment, the following sentence has been deleted from the
SAI:
"In addition, the Adviser or Sub-Adviser may place orders for the purchase or
sale of Fund securities with qualified broker-dealers that refer prospective
shareholders to the Funds."

In addition, the following paragraph has been deleted from the SAI:
"Consistent with the Conduct Rules of the National Association of Securities
Dealers, Inc. ("NASD") and subject to seeking best execution and such other
policies as the Board of Trustees may determine, the advisers may consider sales
of the Fund's shares as a factor in the selection of broker-dealers to execute
portfolio transactions for the Fund";

and replaced with the following paragraph:

"The advisers are not permitted to compensate a broker-dealer for selling fund
shares by directing a portfolio transaction to that broker dealer and will not
consider sales of a Fund's shares as a factor in the selection of broker-dealers
to execute portfolio transactions for a Fund. Nonetheless, the fact that a
broker-dealer sells Fund shares does not prohibit an adviser from doing business
with that broker-dealer. Consistent with Rule 12b-1(h)(2) under the 1940 Act,
Liberty Ridge Capital has adopted, and the Trust's Board of Trustees as
approved, policies and procedures reasonably designed to prevent (1) the persons
responsible for selecting brokers and dealers to effect the Fund's portfolio
securities transactions from taking into account the brokers' and dealers'
promotion or sale of Fund shares or shares of any other registered investment
company and (2) the Trust and its investment adviser and principal underwriter
from entering into any agreement (whether oral or written) or other
understanding under which the company directs, or is expected to direct,
portfolio securities transactions, or other remuneration to a broker or dealer
as compensation for the promotion or sale of Fund shares or shares of any other
registered investment company.

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