SecProbe.io

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                             NEW CENTURY PORTFOLIOS
                          40 WILLIAM STREET, SUITE 100
                               WELLESLEY, MA 02481

July 8, 2005

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

U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC  20549

     RE:     NEW CENTURY PORTFOLIOS
             SEC FILE NOS. 33-24041/811-5646
             -------------------------------

Ladies and Gentlemen:

     On June 24, 2005, New Century  Portfolios (the "Trust"),  filed preliminary
proxy  materials  pursuant to paragraph  (a) of Rule 20a-1 under the  Investment
Company  Act  of  1940,  as  amended  (the  "1940  Act")  and  pursuant  to  the
requirements of Rule 14a-6(a) under the Securities  Exchange Act of 1934.  These
proxy  materials were filed in connection with a Special Meeting of Shareholders
to be held on August 17, 2005 (the "Special Meeting").  The proxy materials will
first be sent to shareholders on or about July 8, 2005.

     The  Portfolios of the Trust are the: New Century  Capital  Portfolio,  New
Century  Balanced  Portfolio,  New  Century  Aggressive  Portfolio,  New Century
International Portfolio and New Century Alternative Strategies Portfolio.

     At the Special Meeting, shareholders will be asked to approve or disapprove
separate new investment advisory agreements between the Trust, on behalf of each
Portfolio,  and Weston Financial  Group,  Inc.  ("Weston"),  the Trust's current
investment adviser. These new investment advisory agreements are being submitted
to the Trust in connection with a proposed change in control at Weston.  The new
investment advisory agreements have substantially the same terms and conditions,
including the provisions for fees, as the Trust's  current  investment  advisory
agreements. The Trust also may transact such other business as may properly come
before the Special Meeting or any adjournment thereof.

     On July 1, 2005, John M. Ganley from the Division of Investment  Management
at the U.S. Securities and Exchange Commission (the "Commission") spoke with the
Trust's  outside  counsel,  Terrance  James  Reilly of Greenberg  Traurig,  LLP,
concerning  the  preliminary  proxy  materials.  The  following  responds to Mr.
Ganley's  comments to the  preliminary  proxy  materials,  as  discussed  in the
telephone call of July 1, 2005. The Commission's comments are in italics and the
Trust's response follows below.

<PAGE>

U.S. Securities and Exchange Commission
July 8, 2005
Page 2

1.   THE COMMISSION REQUESTED THAT THE TRUST CLARIFY THE PARAGRAPH FOUND ON PAGE
     12  CONCERNING  WESTON'S  COMPLIANCE  WITH SECTION 15(F) OF THE 1940 ACT BY
     ADDING THE  REQUIREMENTS OF SECTION 15(F) AND THE POSSIBLE  CONSEQUENCES IF
     WESTON WERE UNABLE TO RELY UPON THE SAFE HARBOR PROVISIONS OF SUCH SECTION.

     The Trust has amended the disclosure. It now reads:

          ^SECTION  15(F) OF THE 1940 ACT  PERMITS AN  INVESTMENT  ADVISER TO AN
     INVESTMENT COMPANY TO RETAIN ANY PROFIT FROM THE SALE OF ITS POSITION AS AN
     ADVISER IF: (I) FOR THREE YEARS  THEREAFTER AT LEAST 75% OF THE TRUSTEES OF
     THE  INVESTMENT  COMPANY  ARE NOT  "INTERESTED  PERSONS"  (AS THAT  TERM IS
     DEFINED IN THE 1940 ACT) OF THE  OUTGOING OR INCOMING  INVESTMENT  ADVISER;
     AND (II) THERE IS NOT  IMPOSED AN "UNFAIR  BURDEN" (AS THAT TERM IS USED IN
     THE 1940 ACT) ON SUCH INVESTMENT  COMPANY AS A RESULT OF SUCH  TRANSACTIONS
     OR ANY EXPRESS OR IMPLIED TERMS, CONDITIONS,  OR UNDERSTANDINGS  APPLICABLE
     THERETO. THIS IS REFERRED TO AS A "SAFE HARBOR" PROVISION.  IN AN EFFORT TO
     RELY UPON THE  PROVISIONS  OF  SECTION  15(F) OF THE 1940  ACT,  ONE OF THE
     PROVISIONS  OF THE  AGREEMENT  BETWEEN  WESTON  AND  WASHINGTON  TRUST WITH
     RESPECT TO THE  TRANSACTION  PROVIDES THAT: (i) for a period of three years
     after the  closing  date of the  Transaction,  Washington  Trust  shall not
     cause, and shall use all commercially reasonable efforts not to permit, any
     "interested person" (as that term is defined in the 1940 Act) of Washington
     Trust or  Weston to  become,  or to  continue  as, a member of the Board of
     Trustees,  unless,  taking into account that "interested  person," at least
     75% of the members of the Board of Trustees  are not  "interested  persons"
     (as that term is  defined in the 1940 Act) of  Washington  Trust or Weston;
     and (ii) Washington  Trust shall not engage in or cause,  and shall use all
     commercially   reasonable   efforts  to  prevent  any  person  directly  or
     indirectly  controlling,  controlled  by,  or  under  common  control  with
     Washington  Trust  from  engaging  in or  causing,  any  act,  practice  or
     arrangement  that,  as a result of the  transactions  contemplated  by this
     Agreement or any express or implied  terms,  conditions  or  understandings
     applicable thereto, imposes an "unfair burden" (as that term is used in the
     1940 Act) on any of the  Portfolios  within the meaning of Section 15(f) of
     the 1940 Act. IF THE  REQUIREMENTS OF THE "SAFE HARBOR" ARE NOT MET FOR THE
     REQUISITE  PERIODS,  THEN WESTON MAY BE UNABLE TO RELY UPON THE SAFE HARBOR
     TO SHELTER ANY PROFITS  DERIVED  FROM THE  TRANSFER OF CONTROL OF WESTON TO
     WASHINGTON TRUST.

2.   IN THE SECTION OF THE PROXY MATERIALS  ENTITLED  "TRUSTEES'  CONSIDERATIONS
     AND  RECOMMENDATIONS"  FOUND ON PAGES 12 AND 13, THE  COMMISSION  ASKED FOR
     ADDITIONAL  DISCLOSURE  CONCERNING THE BOARD'S FINDINGS WITH RESPECT TO THE
     FEES PAID BY EACH  PORTFOLIO IN COMPARISON  TO OTHER,  SIMILAR FUNDS WITHIN
     THE INDUSTRY.

     The Trust has amended the disclosure. It now reads:

<PAGE>

U.S. Securities and Exchange Commission
July 8, 2005
Page 3

     In addition,  the TRUSTEES  WERE ADVISED THAT THE  INVESTMENT  ADVISORY FEE
     CHARGED BY THE  ALTERNATIVE  STRATEGIES  PORTFOLIO  WAS  COMPARABLE  TO THE
     INVESTMENT ADVISORY FEES CHARGED BY OTHER SIMILAR FUNDS WITHIN THE INDUSTRY
     AND THAT THE INVESTMENT  ADVISORY FEES CHARGED BY THE OTHER PORTFOLIOS WERE
     HIGHER THAN OTHER SIMILAR FUNDS WITHIN THE INDUSTRY;  HOWEVER, THE CAPITAL,
     BALANCED,  AGGRESSIVE AND  INTERNATIONAL  PORTFOLIOS DID OFFER A BREAKPOINT
     FOR  ASSETS IN EXCESS  OF $100  MILLION  THAT  COULD  LOWER THE  INVESTMENT
     ADVISORY FEES.

3.   IN THE SECTION OF THE PROXY MATERIALS  ENTITLED  "TRUSTEES'  CONSIDERATIONS
     AND  RECOMMENDATIONS"  FOUND ON PAGES 12 AND 13, THE  COMMISSION  ASKED FOR
     ADDITIONAL  DISCLOSURE  CONCERNING THE BOARD'S FINDINGS WITH RESPECT TO THE
     PERFORMANCE OF EACH PORTFOLIO IN COMPARISON TO ITS BENCHMARK.

     The Trust has amended the disclosure. It now reads:

     The trustees noted that FOR THE YEAR-TO-DATE PERIOD ENDED MAY 31, 2005, THE
     AGGRESSIVE  AND  INTERNATIONAL   PORTFOLIOS  HAD  EACH  OUTPERFORMED  THEIR
     RESPECTIVE  BENCHMARKS AND THAT THE CAPITAL,  BALANCED AND THE  ALTERNATIVE
     STRATEGIES  PORTFOLIOS HAD EACH SLIGHTLY  UNDERPERFORMED  THEIR  RESPECTIVE
     BENCHMARKS.  IN GENERAL,  THE TRUSTEES  NOTED THAT The  Portfolios had been
     performing  competitively  in the  industry  and were  pleased  with  their
     results.

4.   IN THE SECTION OF THE PROXY MATERIALS  ENTITLED  "TRUSTEES'  CONSIDERATIONS
     AND RECOMMENDATIONS" FOUND ON PAGES 12 AND 13, THE COMMISSION ASKED WHETHER
     OR NOT THE TRUSTEES HAD CONSIDERED  THE EXTENT TO WHICH  ECONOMIES OF SCALE
     WOULD BE  REALIZED  AS THE  PORTFOLIOS  GROW,  AND  WHETHER  THE FEE LEVELS
     REFLECT  THESE  ECONOMIES OF SCALE FOR THE BENEFIT OF THE  PORTFOLIOS'.  IF
     THIS FACTOR WAS NOT RELEVANT TO THE BOARD'S EVALUATION,  NOTE THIS FACT AND
     DESCRIBE WHY SUCH FACTOR WAS NOT DEEMED RELEVANT.

     See the reply to Item No. 5 (below).

5.   IN THE SECTION OF THE PROXY MATERIALS  ENTITLED  "TRUSTEES'  CONSIDERATIONS
     AND RECOMMENDATIONS" FOUND ON PAGES 12 AND 13, THE COMMISSION ASKED WHETHER
     THE BOARD  RELIED UPON  COMPARISONS  OF THE SERVICES TO BE RENDERED AND THE
     AMOUNTS TO BE PAID UNDER THE  CONTRACT  WITH THOSE UNDER  OTHER  INVESTMENT
     ADVISORY  CONTRACTS,  SUCH AS  CONTRACTS  OF THE SAME AND OTHER  INVESTMENT
     ADVISERS  WITH OTHER  REGISTERED  INVESTMENT  COMPANIES  OR OTHER  TYPES OF
     CLIENTS (E.G.,  PENSION FUNDS AND OTHER INSTITUTIONAL  INVESTORS).  IF THIS
     FACTOR  WAS NOT  RELEVANT  TO THE  BOARD'S  EVALUATION,  NOTE THIS FACT AND
     DESCRIBE WHY SUCH FACTOR WAS NOT DEEMED RELEVANT.

     The Trust has added the  following  disclosure  which applies to both Items
     Nos. 4 and 5:

<PAGE>

U.S. Securities and Exchange Commission
July 8, 2005
Page 4

          IN THEIR  DELIBERATIONS,  THE  TRUSTEES DID NOT CONSIDER THE EXTENT TO
     WHICH  ECONOMIES OF SCALE WOULD BE REALIZED AS A PORTFOLIO  GROWS,  NOR DID
     THEY RELY UPON  COMPARISONS  OF THE SERVICES TO BE RENDERED AND THE AMOUNTS
     TO BE PAID UNDER THE CONTRACT  WITH THOSE UNDER OTHER  INVESTMENT  ADVISORY
     CONTRACTS, SUCH AS CONTRACTS OF THE SAME AND OTHER INVESTMENT ADVISERS WITH
     OTHER  REGISTERED  INVESTMENT  COMPANIES  OR OTHER TYPES OF CLIENTS  (E.G.,
     PENSION  FUNDS AND  OTHER  INSTITUTIONAL  INVESTORS).  THESE  FACTORS  WERE
     CONSIDERED  NOT TO BE RELEVANT IN THIS  SITUATION  WHERE THE TRUSTEES  WERE
     TRYING TO  APPROVE  NEW  AGREEMENTS  ON  SUBSTANTIALLY  THE SAME  TERMS AND
     CONDITIONS  AS THE  CURRENT  ADVISORY  AGREEMENTS.  SUCH  FACTORS  WOULD BE
     RELEVANT TO CONSIDERING  AND APPROVING NEW INVESTMENT  ADVISORY  AGREEMENTS
     WITH OTHER INVESTMENT ADVISORY ENTITIES.

6.   ADD THE APPROPRIATE "TANDY" REPRESENTATIONS.

     In  responding  to the  Commission's  comments,  please note that the Trust
     hereby acknowledges and represents:

          o    The Trust is  responsible  for the  adequacy  and accuracy of the
               disclosure in these proxy materials;
          o    Staff  comments  or changes to  disclosure  in  response to staff
               comments  in these  proxy  materials,  which was  reviewed by the
               staff,  does not foreclose the Commission  from taking any action
               with respect to these proxy materials; and
          o    The Trust  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.

     Questions  concerning  this letter may be directed to the Trust's  counsel,
Terrance  James  Reilly  at  (215)  988-7815,  or  in  his  absence,  Steven  M.
Felsenstein at (215) 988-7837.

                                                     Very truly yours,

                                                     /s/ Nicole M. Tremblay
                                                     Nicole M. Tremblay

cc:     Steven M. Felsenstein
        Jackson B. R. Galloway
        John M. Ganley
        Wayne M. Grzecki
        Terrance James Reilly

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