SecProbe.io

CORRESP
1
filename1.htm

Correspondence

Thrivent Mutual Funds

625 Fourth Avenue South

Minneapolis, Minnesota 55415

February 18, 2005

                                                       VIA EMAIL

Mr. Dominick Minore

United States Securities and Exchange Commission

Division of Investment Management

450 Fifth Street, N.W.

Washington, DC  20549-0506

RE:         Thrivent Mutual Funds, 1933 Act file no. 33-12911

Dear Mr. Minore:

Thank you for the  additional  comments on behalf of the staff (the  "Staff")  of the  Securities  and  Exchange  Commission  regarding
Post-Effective  Amendment No. 54 to the registration  statement filed on Form N-1A for the above-referenced  Registrant.  The following
is a description of those comments  raised by you on behalf of the Staff,  along with a description of Registrant's  proposed  response
to each comment.  Subject to further  comments from the Staff,  Registrant  represents  that it will make the revisions  noted below in
the post-effective amendment that will be filed prior to the effective date.

   With respect to the previous comments  regarding the disclosure  regarding whether  Registrant  accommodates  frequent trading
     and Registrant's  proposed  additional  sentence  following the first sentence of the section titled "Abusive Trading Policies and
     Monitoring  Processes," the Staff commented that Registrant  should identify the types of transactions  for which frequent trading
     is  accommodated.  Registrant  will insert the  following  words after  "Except as described  below":  "with  respect to automatic
     investment plans, systematic withdrawal plans, transactions soley in your money market account, or omnibus accounts".

     With  respect to the  previous  comments  regarding  the  disclosure  about  Registrant's  right to cancel a  transaction  and
     Registrant's  responses  thereto,  the  Staff  asked  whether  "promptly"  means  within  one day.  Registrant  confirms  that any
     cancellations described in the additional disclosure will be made within one day.

Registrant hereby acknowledges that:

    The Funds are responsible for the adequacy and accuracy of the disclosure in the filings;

     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 filing; and

      The 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.

Very truly yours,

/s/ John C. Bjork

John C. Bjork

Assistant Secretary

Thrivent Mutual Funds

625 Fourth Avenue South

Minneapolis, Minnesota 55415

February 18, 2005

                                                       VIA EMAIL

Mr. Dominick Minore

United States Securities and Exchange Commission

Division of Investment Management

450 Fifth Street, N.W.

Washington, DC  20549-0506

RE:         Thrivent Mutual Funds, 1933 Act file no. 33-12911

Dear Mr. Minore:

Thank  you for  additional  comments  on  behalf of the staff  (the  "Staff")  of the  Securities  and  Exchange  Commission  regarding
Post-Effective  Amendment No. 54 to the registration  statement filed on Form N-1A for the above-referenced  Registrant.  The following
is a description of those comments  raised by you on behalf of the Staff,  along with a description of Registrant's  proposed  response
to each comment.  Subject to further  comments from the Staff,  Registrant  represents  that it will make the revisions  noted below in
the post-effective amendment that will be filed prior to the effective date.

      With respect to the previous  comment  regarding the potential for special risks related to the frequent trading in high yield
     and  international  funds and  Registrant's  response  that there are no greater  risks for those  securities  because of its fair
     valuation  procedures,  the Staff commented that the section titled "Abusive  Trading  Policies and Monitoring  Processes"  should
     specifically  reference the potential for greater risks of abusive trading for funds with those types of securities and that those
     risks are minimized because of Registrant's fair valuation  procedures.  Registrant  proposes to revise the second sentence of the
     second paragraph of that section to state (with the new language  reflected by  underlining):  "The Funds may use a combination of
     monitoring shareholder activity and restricting shareholder  transactions on certain accounts to combat market timers. The Funds'
     use of fair value pricing  procedures also reduces the opportunities for market timers,  especially for the Funds with securities
     that pose more frequent pricing challenges,  such as international securities,  high yield securities, and other securities whose
     market prices may not accurately reflect their fair value (see "Pricing Funds' Shares").

      With respect to the previous  comment  regarding the disclosure  about whether  Registrant  accommodates  frequent trading and
     Registrant's  proposed  additional  sentence  following the first sentence of the section  titled  "Abusive  Trading  Policies and
     Monitoring  Processes," the Staff commented that the exception in the first part of the additional  sentence may not be necessary.
     As we discussed,  Registrant  accommodates  frequent trading with respect to automatic  investment  plans,  systematic  withdrawal
     plans,  transactions  in the money  market  fund,  or omnibus  accounts.  As a result,  Registrant  respectfully  submits that the
     proposed revision is appropriate.

      With  respect  to the  previous  comment  regarding  the  disclosure  about  Registrant's  right to cancel a  transaction  and
     Registrant's  response  thereto,  the Staff commented that Registrant should disclose its policies  regarding  cancellation in the
     section titled "Abusive Trading Policies and Monitoring  Processes."  Registrant proposes to add the following additional sentence
     to the end of the fifth  paragraph of that  section:  "If it becomes  necessary to cancel a  transaction  of a  shareholder  whose
     account has been  restricted,  the Funds will promptly  reverse the exchange or (if the purchase request is not associated with an
     exchange) refund the full purchase price to the shareholder."

Registrant hereby acknowledges that:

     The Funds are responsible for the adequacy and accuracy of the disclosure in the filings;

      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 filing; and

     The 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.

Please  let me know as soon as  possible  whether  you have any  additional  comments  regarding  the  above-referenced  post-effective
amendment.

Very truly yours,

/s/ John C. Bjork

John C. Bjork

Assistant Secretary

February 16, 2005

                                                       VIA EMAIL

Mr. Dominick Minore

United States Securities and Exchange Commission

Division of Investment Management

450 Fifth Street, N.W.

Washington, DC  20549-0506

RE:         Thrivent Mutual Funds, 1933 Act file no. 33-12911

Dear Mr. Minore:

Thank you for taking the time to talk with me yesterday  with respect to the comments of the staff (the "Staff") of the  Securities and
Exchange  Commission  regarding   Post-Effective  Amendment  No.  54  to  the  registration  statement  filed  on  Form  N-1A  for  the
above-referenced  Registrant.  The  following  is a  description  of the  comments  raised by you on behalf of the Staff,  along with a
description of  Registrant's  proposed  response to each comment.  Subject to further  comments from the Staff,  Registrant  represents
that it will make the revisions noted below in the post-effective amendment that will be filed prior to the effective date.

      The Staff  asked  Registrant  to  disclose  that  redemption  for small  accounts  may be at a time that is not  favorable  to
     investors.  Registrant  proposes to add the following  sentence prior to the last sentence of that section:  "If additional shares
     are not purchased, any such redemption may be at a time that is not favorable to you."

      The Staff asked Registrant to disclose any special risks related to the frequent  trading in its high yield and  international
     funds.  There are no greater risks for those funds.  As discussed  under the section  titled  "Pricing  Funds' Shares" and also in
     the section titled "Abusive Trading Policies and Monitoring  Processes,"  Registrant will price a security according to fair value
     procedures  approved  by the Board of  Trustees  if the market  price of a security is not  available  or the  investment  adviser
     determines that the market price does not accurately reflect its fair value.

      The Staff asked  Registrant to disclose in the section titled  "Abusive  Trading  Policies and Monitoring  Processes"  whether
     Registrant  accommodates frequent trading.  Registrant proposes to add the following sentence following the first sentence of that
     section:  "Except as discussed  below,  the Funds do not  accommodate  frequent  purchases and  redemptions of Fund shares by Fund
     shareholders."

      The Staff asked  Registrant to disclose in the section titled  "Abusive  Trading  Policies and Monitoring  Processes"  whether
     Registrant's  policies  apply  uniformly.  Registrant  proposes to add the  following  sentence as the last sentence in the second
     paragraph of that section:  "Except as noted below, these policies apply uniformly to all shareholders."

     The Staff asked  Registrant to clarify in the last sentence of the fourth  paragraph of the section  titled  "Abusive  Trading
     Policies and  Monitoring  Processes"  what is intended by the words  "restrict"  or "cancel" at the end of that  paragraph.  Since
     Registrant  discloses that it may restrict the number or frequency of exchanges earlier in the paragraph,  it will delete the word
     "restrict" in the last sentence of the paragraph.  Registrant may cancel a purchase  request if it mistakenly  allowed an order to
     be processed for an investor  whose trading  privileges  were  restricted.  If such an order is mistakenly  processed,  Registrant
     will cancel the order within one or two days and refund the full purchase price to the investor.

    The Staff  commented  with  respect to the  section  titled  "Pricing  Funds'  Shares"  that  Registrant  should  refer to the
     Instructions  to Item 6(a) with respect to any portion of the Funds shares that are  invested in other  mutual  funds.  Registrant
     proposes to add the  following  sentence at the end of the third  paragraph of that  section:  "For any portion of a Fund's assets
     that are invested in other mutual funds,  the NAV is calculated  based upon the NAV of the mutual funds in which the Fund invests,
     and the prospectuses for those mutual funds explain the circumstances under which they will use fair value pricing."

    The Staff commented with respect to the section titled  "Disclosure of Portfolio  Holdings" in the SAI that Registrant  should
     consider  moving the fifth  paragraph up so it becomes the second  paragraph in that  section.  Registrant  will make that change.
     In the same  paragraph,  Registrant  will add the  following  sentence as the  second-to-the-last  sentence of the  paragraph,  as
     suggested by the Staff:  "Accordingly,  all of the persons with whom an arrangement is made for  non-public  disclosure  will have
     satisfied the aforementioned requirements."

    The Staff  commented with respect to the current third paragraph of the section titled  "Disclosure of Portfolio  Holdings" in
     the SAI that the list of identified  persons  should be exclusive.  Registrant  will remove the ", without  limitation,"  from the
     second sentence of that paragraph and will remove "certain other parties, such as" from the last sentence of that paragraph.

     The Staff  commented  that the  instructions  to Item 11(f)  require the Funds to include  any  policies of the adviser or any
     other person with respect to the  disclosure of the Funds'  portfolio  securities.  The policies  described in the section  titled
     "Disclosure  of  Portfolio  Holdings"  in the SAI  apply to  Registrant's  affiliated  investment  adviser  and  sponsor.  Neither
     Registrant's  subadvisers  nor any other third party have policies with respect to the  disclosure of portfolio  securities of its
     Funds.

    The Staff asked with  respect to the current  fourth  paragraph  of the section  titled  "Disclosure  of  Portfolio  Holdings"
     whether any of the  entities in the current  sixth  paragraph  of that  section are  "intermediaries  that  distribute  the Fund's
     shares."  They  are not.  For  clarification,  Registrant  proposes  to end the  current  fourth  paragraph  after  "institutional
     investors." In the same current fourth  paragraph,  the Staff commented that the second sentence should be more precise instead of
     stating  "Thrivent does not expect to disclose . . . " Registrant  proposes to substitute the words "will not" for the words "does
     not expect to" in that sentence.

    The Staff  commented with respect to Item  11(f)(1)(vi)  that the section titled  "Disclosure  of Portfolio  Holdings"  should
     state that any such  disclosure  is in the best  interests  of its  shareholders.  The current  fifth  paragraph  of that  section
     discloses the requirements for non-public  disclosure of information,  including that Registrant's  Chief Compliance  Officer or a
     designated  attorney  acting upon behalf of Registrant  will determine "that the disclosure is in the best interests of the Fund's
     shareholders."

    The Staff commented that the section titled  "Disclosure of Portfolio  Holdings" should identify any procedures to monitor the
     use of the portfolio  holdings  information  that is provided to the entities  identified  in the current sixth  paragraph of that
     section.    Registrant does not have procedures to monitor such use of the portfolio information.

Registrant hereby acknowledges that:

     The Funds are responsible for the adequacy and accuracy of the disclosure in the filings;

     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 filing; and

      The 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.

Please  let me know as soon as  possible  whether  you have any  additional  comments  regarding  the  above-referenced  post-effective
amendment.

Very truly yours,

/s/ John C. Bjork

John C. Bjork

Assistant Secretary