SecProbe.io

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August 31, 2004

VIA EDGAR TRANSMISSION
----------------------

Ms. Kimberly Browning, Esquire
Securities and Exchange Commission
Division of Investment Management
450 Fifth Street, N.W.
Washington, DC 20549

RE:      Armada Funds ("Registrant")
         Registration Statement No. 333-117172

Dear Ms. Browning:

         On behalf of the Registrant, this letter responds to the comments of
the Commission staff regarding the Registration Statement on Form N-14 filed on
July 6, 2004 relating to the proposed reorganization of the Riverfront Large
Company Select Fund, Riverfront Balanced Fund, Riverfront Small Company Select
Fund, Riverfront Select Value Fund, Riverfront U.S. Government Fund, and
Riverfront U.S. Government Securities Money Market Fund (each, a "Riverfront
Target Fund" and collectively, the "Riverfront Target Funds"), each a series of
The Provident Riverfront Funds into the Registrant's Large Cap Growth Fund,
Balanced Allocation Fund, Small Cap Growth Fund, Large Cap Value Fund,
Government Mortgage Fund and Government Money Market Fund (each, an "Armada
Acquiring Fund" and collectively, the "Armada Acquiring Funds") (the "Proposed
Reorganization"). The staff's comments to Form N-14 and the Registrant's
responses thereto are set forth below. The responses are reflected in the
pre-effective amendment to the Registration Statement filed on August 31, 2004.
As applicable, cross-references to page numbers are noted with the response.
<PAGE>

Comments to the Shareholder Letter, Q&A, and Combined Prospectus/Proxy Statement
("Prospectus/Proxy")

1.       Comment: The staff requested that the Registrant utilize another term
         for the "Acquired Funds" so as to make more clear to shareholders which
         funds are the target of the Proposed Reorganizations and to make this
         change throughout the entire document.

         Response: The disclosure has been revised to define the term "Acquired
         Fund" as "Riverfront Target Fund" throughout the Prospectus/Proxy and
         Statement of Additional Information ("SAI"). In addition, the
         disclosure has been revised to define the term "Acquiring Fund" as
         "Armada Acquiring Fund" throughout the Prospectus/Proxy and SAI. To
         avoid confusion, the revised defined terms will be used throughout
         these responses even where quoting from the text of the Form N-14 as
         filed on July 6.

2.       Comment: The staff requested that the discussion concerning
         deliberations of the Board of Trustees of The Provident Riverfront
         Funds in deciding to approve the Proposed Reorganizations be modified
         to more specifically discuss the Board's considerations and its
         reasoning for approving the Proposed Reorganizations, as well as the
         Interim Agreement and New Agreement, as opposed to a bullet point list
         of factors.

         Response: Registrant has revised the disclosure in the Prospectus/Proxy
         under the heading "PROPOSAL 1- APPROVAL OF THE REORGANIZATION PLAN -
         Board Approval of the Reorganization Plan" to provide greater details
         concerning the considerations of the approval of the Proposed
         Reorganizations by the Board of Trustees of The Provident Riverfront
         Funds and recommending to shareholders of the Riverfront Target Funds
         that they approve the Proposed Reorganizations. See pages 71-72. The
         Trustees have reviewed with their counsel the revised disclosure
         concerning their deliberations and determined that the disclosure
         accurately reflects their considerations. The presentation in the
         shareholder letter has been revised somewhat but remains in bullet
         point format as a summary of the Board's considerations.

3.       Comment: In the shareholder letter, second page, second bullet point,
         the staff requested that the Registrant explain "enhanced viability."

         Response:  After review, Registrant determined to eliminate "enhanced
         viability."
<PAGE>

4.       Comment: In the shareholder letter, second page, fourth bullet point,
         the staff indicated that the statement that "Shareholders of the
         Riverfront Target Funds are expected to pay lower or the same advisory
         fees after the Reorganizations" is incorrect since some of the
         Riverfront Target Funds have lower advisory fees than their
         counterpart. The staff requested Registrant to please explain and
         revise the statement accordingly.

         Response: After review of the advisory fees, Registrant has deleted
         this bullet point from the shareholder letter.

5.       Comment: In the shareholder letter, second page, fifth bullet point, as
         well as in other sections of the Prospectus/Proxy, the staff indicated
         that in order to state that net operating expense ratios of the Armada
         Acquiring Funds are lower than those of the Riverfront Target Funds the
         calculation must be made before any waivers are taken into account.

         Response: Registrant has revised the representations in what is now the
         third bullet point and in the Q&A under the heading "Will the fees and
         expenses of my Riverfront Target Fund increase?" to accurately describe
         the differences in total annual fund operating expenses shareholders of
         the Riverfront Target Funds will experience as a result of the Proposed
         Reorganizations.

6.       Comment: In the shareholder letter, second page, sixth bullet point and
         in applicable sections of the Prospectus/Proxy, the staff commented
         that Registrant should be sure to discuss the material differences in
         investment objectives and strategies.

         Response: Registrant has reviewed, and made minor revisions to, the
         disclosure and believes it fully describes the investment objectives
         and principal investment strategies of the Riverfront Target Funds and
         Armada Acquiring Funds and all material differences between them.

7.       Comment: The staff requested that the Registrant specify that
         shareholders of the Riverfront Target Fund will be subject to sales
         loads for any future purchases of Armada Acquiring Fund shares after
         the Proposed Reorganizations are completed.

         Response: Registrant has revised certain sections of the
         Prospectus/Proxy to provide further information about the sales loads
         that shareholders of the Riverfront Target Funds may incur if they
         approve the Proposed Reorganization and become shareholders of the
         Armada Acquiring Funds. Registrant has also added disclosure that, if
         shareholders of the Riverfront Target Funds approve the Proposed
         Reorganizations and become shareholders of the Acquiring Funds, they
         will incur applicable sales loads on any new purchases made in the
         Acquiring Funds.
<PAGE>

8.       Comment: The staff requested that the Registrant explain why the Board
         of Trustees of The Provident Riverfront Funds included as a factor in
         both the shareholder letter and in the Prospectus/Proxy that the
         Riverfront Target Fund shareholders will have the opportunity to vote
         on the Proposed Reorganizations when it is required by law to have
         shareholder approval.

         Response: The Provident Riverfront Funds' Declaration of Trust governs
         when shareholders must vote on a sale or disposition of assets and such
         Declaration of Trust requires a vote under such circumstances only if
         required by the Investment Company Act of 1940, or to the extent the
         Board considers such a vote to be necessary or advisable. (See Sections
         5.1 and 7.2 of The Provident Riverfront Funds' Declaration of Trust, as
         amended). In this case, Registrant proposed, and The Provident
         Riverfront Funds' Board approved, the Proposed Reorganizations making
         their completion subject to shareholder approval. Under the
         circumstances disclosure of such fact is appropriate.

9.       Comment: Specifically disclose whether the Armada Acquiring Funds'
         Board of Trustees determined whether there would be any dilution as a
         result of the Proposed Reorganizations and if the Proposed
         Reorganizations are in the best interests of the Armada Acquiring
         Funds' shareholders.

         Response: Disclosure has been added to make more clear that the Armada
         Acquiring Funds' Board of Trustees also determined that the Proposed
         Reorganizations would not result in the dilution of the interests of
         shareholders of the Armada Acquiring Funds and that the Proposed
         Reorganizations are in the best interests of the Armada Acquiring
         Funds' shareholders. See pages 6 and 71.

10.      Comment: Represent supplementally that the Interim Agreement between
         The Provident Riverfront Funds and National City Investment Management
         Company, Inc. ("IMC") was approved before the July 1, 2004 merger
         between National City Corporation, the indirect parent of IMC, and
         Provident Financial Group, Inc., the parent of Provident Investment
         Advisors, Inc., the previous investment adviser to the Riverfront
         Target Funds.

         Response: As disclosed in the Prospectus/Proxy on the second page of
         the shareholder letter and pages 2 and 7 of the Prospectus/Proxy, the
         Board of Trustees of The Provident Riverfront Funds approved the
         Interim Agreement at a Special Meeting held on June 23, 2004.
<PAGE>

11.      Comment: Clarify what the consequences will be if shareholders of the
         Riverfront Target Funds do not vote to approve the Proposed
         Reorganizations and/or New Agreement.

         Response: In the shareholder letter, disclosure has been revised to
         clarify what would occur if the new advisory agreement is approved for
         a Riverfront Target Fund, but its Reorganization is not approved. The
         disclosure has been revised to state: "If the new advisory agreement is
         approved for a Riverfront Target Fund, but its Reorganization is not
         approved, the new investment advisory agreement will go into effect and
         IMC will continue to provide investment advisory services to the
         Riverfront Target Fund. If the Reorganization is not approved for any
         Riverfront Target Fund, the Board would consider what alternatives
         reasonably would be available at that point, including the termination
         of such Riverfront Target Fund."

         Similarly, on page 77 of the Combined Prospectus/Proxy Statement the
         disclosure has been revised to state: "Therefore, in the event that the
         New Agreement is not approved by a Riverfront Target Fund and its
         Reorganization is not completed by November 28, 2004, the Board would
         consider what alternatives reasonably would be available at that point,
         including the termination of such Riverfront Target Fund or the hiring
         of a new investment adviser, subject to shareholder approval, if an
         appropriate adviser could be retained to manage the assets remaining of
         such Riverfront Target Fund."

12.      Comment: Add an explanation of why the Armada Acquiring Funds'
         shareholders do not have to approve the Proposed Reorganization.

         Response: In the Q&A section, under the heading "Will my vote make a
         difference?" the following sentence has been added: "Armada Funds'
         Declaration of Trust does not require shareholders of the Armada
         Acquiring Funds to approve the Reorganizations and shareholders of the
         Armada Acquiring Funds will not vote on the proposals."

13.      Comment: Add the dates that the Board of Trustees of The Provident
         Riverfront Funds met with representatives of IMC and Armada Funds to
         discuss the Proposed Reorganization.

         Response: Since there was a series of discussions among the various
         parties to the Proposed Reorganizations, the following disclosure has
         been revised in the Q&A under the heading "Why are the Reorganizations
         being recommended?" to read: "The Board of Trustees met with
         representatives of IMC and Armada Funds during May and June of 2004."
         Specific Board meeting dates have already been disclosed in the
         appropriate sections of the Prospectus/Proxy Statement.
<PAGE>

14.      Comment: Explain supplementally why the "Other Expenses" for the
         Riverfront Target Funds are much higher than those of the Armada
         Acquiring Funds.

         Response: The Riverfront Target Funds have a much smaller asset base
         over which to spread those costs than the Armada Acquiring Funds.

15.      Comment: In the Q&A, further explain in the fourth bullet point under
         the heading "What are the benefits of the Reorganizations?" what is
         meant by "strong performance record."

         Response: In response to this comment, Registrant has revised the
         fourth bullet point to state the following: "The Armada Acquiring Funds
         have strong performance records that compare favorably to the
         Riverfront Target Funds. For example, the 2003 calendar year total
         returns (before sales charges) for Investor A Shares of the Riverfront
         Target Funds and Class I Shares of the Armada Acquiring Funds were:

                  Riverfront Large Company Select Fund        21.60%
                  Armada Large Company Growth Fund            20.10%

                  Riverfront Balanced Fund                    16.34%
                  Armada Balanced Allocation Fund             22.26%

                  Riverfront Small Company Select Fund        44.89%
                  Armada Small Cap Growth Fund                45.43%

                  Riverfront Select Value Fund                26.27%
                  Armada Large Cap Value Fund                 27.18%

                  Riverfront U.S. Government Fund             2.27%
                  Armada Government Mortgage Fund             2.13%

                  Riverfront U.S. Government Securities
                      Money Market Fund                       0.43%
                  Armada Government Money Market Fund         0.74%
<PAGE>

                  More performance information is contained in the Combined
                  Prospectus/Proxy Statement."

16.      Comment: Make clear what classes of shares shareholders of the
         Riverfront Acquired Funds will receive as a result of the Proposed
         Reorganization as well as the Board of Trustees' reasoning for why the
         corresponding classes of shares to be received in the Proposed
         Reorganizations are appropriate.

         Response: In the Q&A under the heading "What class of shares of the
         Armada Acquiring Funds will I receive in the Reorganization?" the
         disclosure has been revised to add a table showing the specific class
         of shares that shareholders of the Riverfront Target Fund will receive.
         In addition, the following disclosure has been added: "Class I Shares
         of the Armada Acquiring Funds are considered to be an appropriate share
         class to exchange for Investor A Shares of the Riverfront Target Funds
         in the Reorganizations because many shareholders of the Riverfront
         Target Funds' Investor A Shares meet the eligibility requirements for
         purchase of Class I Shares of the Armada Acquiring Funds. Class A
         Shares of the Armada Acquiring Funds are