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INTEGRITY VIKING FUNDS

1 North Main Street

Minot, North Dakota 58703

January 16, 2025

VIA EDGAR Transmission

U.S. Securities and Exchange
Commission

Office of Disclosure and Review

Attn: Christina DiAngelo
Fettig (202) 551-6963

450 Fifth Street, N.W.

Washington, D.C. 20549

Re:    Integrity Funds - File No.: 811-07322

Viking
Mutual Funds – File No.: 811-09277

            RE: Response to
comments received on the Sarbanes-Oxley review of the report filings for the
following funds managed by Viking Fund Management, LLC, a wholly owned
subsidiary of Corridor Investors, LLC:

Fund                                                                Fiscal
Year-End                                  811#

The Integrity Funds                                          July
31, 2024                                       811-07322

Integrity
High Income Fund

Integrity
Growth & Income Fund

Integrity
Dividend Harvest Fund

Integrity
Dividend Summit Fund

Integrity
Mid-North American Resources Fund

Integrity
Short Term Government Fund

Viking Mutual Funds                                       July 31, 2024                                       811-09277

Kansas
Municipal Fund

Nebraska
Municipal Fund

Oklahoma
Municipal Fund

Maine
Municipal Fund

Viking
Tax-Free Fund for Montana

Viking
Tax-Free Fund for North Dakota

1

Ms. DiAngelo:

Below
are each of the comments received on report filings reviewed by the Office of
Disclosure and Review.

1. Diversification question

COMMENT:

The
Oklahoma Municipal Fund is categorized as diversified. It appears that issuers
representing more than 5% of total assets were about 28% of assets as of the
end of the July 31, 2024 reporting period. Please explain how the Fund is
considered diversified.

RESPONSE: Based on the Oklahoma
Fund’s diversification calculation as of July 31, 2024, issuers representing
over 5% of total assets were at 17.61%, and issuers representing under 5% of
total assets and all other allowable assets totaled 82.39%. Although the
Schedule of Investments at July 31, 2024 categorized the bond holdings by industry
and lists the name of each bond by the bond authority, diversification is
calculated and tested using the actual underlying issuer of the bond, which may
differ from the finance authority that acted as the conduit for the offering. For
example, there were ten bonds on the Schedule of Investments at July 31, 2024,
with the name of Oklahoma Development Finance Authority (“ODFA”), totaling
13.09% of total assets. For the first 4 bonds listed below representing 2.85%
of total assets, ODFA acted purely as the conduit to facilitate the offering.
In these deals, the ODFA has no obligation to pay the debt, and creditors look
solely to the underling issuer as the obligor. For the other ODFA positions,
ODFA is the obligor and regarded as the issuer. The ODFA bonds represented
10.24% of total assets. There were other municipal bonds in the portfolio that
are considered in the same manner as below, resulting in the diversified status
of the Oklahoma Municipal Fund.

2. Significant portion of securities of companies that comprise the
Information Technology sector

COMMENT:

The
Schedule of Investments portion of the Annual Report with respect to the
Integrity Growth & Income Fund (“G&I Fund”) indicates that the G&I
Fund held a significant portion of its assets in securities of companies that
comprise the Information Technology sector as of the end of the fiscal year.
Registrant should consider adding a risk factor to its prospectus related to
investments in the Information Technology sector.

RESPONSE:

The Registrant has filed a Supplement
dated January 14, 2025 to the Summary Prospectus dated December 2, 2024 and the
Prospectus dated November 30, 2024, with the following information:

2

The “Principal Investment Strategies” section in the
Fund’s Summary Prospectus and Prospectus are supplemented with the following:

While
the Fund does not concentrate in any one industry, based on economic
conditions, it may make significant investments in certain sectors.

The
“Principal Risks” sections in the Fund’s Summary Prospectus and
Prospectus are supplemented with the following:

Risks
of the Information Technology Sector:
The Fund may invest significantly in securities of companies in the information
technology sector, and will therefore be susceptible to adverse economic,
business, political, environmental, regulatory, or other occurrences affecting
that sector. Information technology companies face intense competition, both
domestically and internationally, which may have an adverse effect on profit
margins. Information technology companies may have limited product lines,
markets, financial resources or personnel. The products of information
technology companies may face obsolescence due to rapid technological
developments and frequent new product introduction, unpredictable changes in
growth rates and competition for the services of qualified personnel. Companies
in the information technology sector are heavily dependent on patent and
intellectual property rights. The loss or impairment of these rights may
adversely affect the profitability of these companies.

3. NAV error question

COMMENT:

Regarding
the checkbox marked YES on Item B22 of Form N-CEN for the July 31, 2023
reporting period of the Kansas Municipal Fund, please describe in
correspondence the nature and circumstances of the error, any associated
internal control implications, and amounts reimbursed, if any.

RESPONSE:

Item B.22. of Form N-CEN for
the July 31, 2023 reporting period for Kansas Municipal Fund was incorrectly
marked as YES. There was an NAV error that required reimbursement to the Fund
but shareholder accounts were not required to be reprocessed based on the
amount of the error. Incorrect yields for January 3, 2023 were entered into the
municipal bond matrix by the pricing analyst. January 3, 2023 was the first
business day of the new calendar year. An adjustment should have been made to
the yields obtained from S&P Global (fka Refinitive) per the Municipal
Market Monitor (TM3) reports for the year-end roll. This error was discovered
the following morning, January 4, 2023 and corrections to the securities values
were immediately and appropriately made. The Net Asset Value was off by $.02
for Class A of the Kansas Municipal Fund and resulted in a $20.68 gain based on
shareholder activity for January 3, 2023. Class I Net Asset Value of the same
Fund was off by $0.01 (the $0.01 difference was due to rounding) and resulted
in a loss of $44.85 based on shareholder activity. The $44.85 was reimbursed to
Kansas Municipal Fund Class I by Integrity Fund Services, LLC. To ensure this
error does not occur in the future, pricing and review procedures were enhanced
and communication with the pricing vendor occurs when unusual changes show on
the TM3 reports.

4. When-issued securities

COMMENT:

For
both of the Registrants, The Integrity Funds and Viking Mutual Funds (the
“Funds”), please explain whether FORM N-CEN item C.7 n. (vi) should have been
checked for any of the Funds. Did the Fund invest in a security on a
when-issued or forward-settling basis, or with a non-standard settlement cycle,
in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))?

RESPONSE:

The
Registrant initially determined that the Funds were not relying on Rule
18f-4(f) which resulted in the responses to the Funds’ Form N-CEN item C.7 n (vi).
Per the Funds’ Rule 18f-4(f) Procedures, the Funds will
not engage in transactions that would be considered “derivatives” for purposes
of Rule 18f-4 without the prior consent of the Investment Compliance Committee
and amendment, if applicable, of these procedures to comply with Rule 18f-4. The
Funds invest in when-issued securities periodically. These when-issued
purchases are considered eligible delayed delivery securities and are not
considered derivatives. Based on review of the Rule, Paragraph 18f-4(f)
provides that delayed delivery securities are not considered Derivatives if (1)
the trade settles within 35 days of its trade date, and (2) the Fund intends to
physically settle the trade rather than engage in an offsetting transaction. Viking
Fund Management (Adviser) and Integrity Fund Services, LLC (Fund Accountant)
monitor trading activity to ensure all trades settle within 35 days of trade
date. After further review and based on the Funds use of when-issued securities,
it was determined that reliance is placed on Rule 18f-4(f). Item C.7.n.(vi) of
Form N-CEN will be checked on future filings.

3

The following comments and responses relate to the Tailored Shareholder
Reports.

5. Amend N-CSR

COMMENT:

We
recognize the amended N-CSR for The Integrity Funds and Viking Mutual Funds to
include the audit opinion. It appears the most recent filings has the audit
opinion under item 6 as opposed to item 7. On the Integrity Viking Fund website
the audit opinion is under item 7. Please amend both the N-CSRs to reflect the
information on the Funds’ website. The schedule of investments is also under
item 7 on the Fund website and should be under item 7 of the N-CSR as well. The
titles and the dates of the schedule of investments should also be amended on
the N-CSR to be consistent with the Fund website.

RESPONSE:

The amended Forms N-CSR for The
Integrity Funds and Viking Mutual Funds were filed on December 6, 2024 and
include the above mentioned changes.

6. Tailored Shareholder Report conform to FORM N-1A

COMMENT:

Item
27A(b)4 of the N-1A is a requirement for the following statement:

This [annual or semi-annual]
shareholder report contains important information about [the Fund] for the
period of [beginning date] to [end date]. You can find additional information
about the Fund at [______]. You can also request this information by contacting
us at [______]

In the tailored shareholder
reports, please state annual or semi-annual in the introductory statement on
the first page.

RESPONSE:

This change will be made on all future
Tailored Shareholder Reports’ filings beginning with the January 31, 2025
semi-annual report.

7. Fund expense information

COMMENT:

Reference U.S. Securities and
Exchange Commission ADI 2024-14 (“ADI”). Under the ADI section 1.b, note that
funds must multiply the figure in the “cost paid as a percentage of your
investment’ column by the average account value over the period based on an
investment of $10,000 at the beginning of the period. The amount is computed
using the average account value over the period and not just the straight
multiplication of $10,000 by the expense ratio. This would include performance.
See Instruction 2(a) to Item 27A(c) of Form N-1A.

4

RESPONSE:

This change will be made on all future
Tailored Shareholder Reports’ filings beginning with the January 31, 2025
semi-annual report.

8. Cumulative performance chart without CDSC

COMMENT:

Please
explain why the cumulative performance chart was calculated without CDSC. Say
for example it did not apply.

RESPONSE:

CDSC
does not apply to the time periods presented in the line graph, therefore, it
was not included.

9. Broad-based index

COMMENT:

Reference
27A(d)2 of the N-1A instruction 8. Please provide a disclosure for the reason
for the change in the broad-based index.

RESPONSE:

The Registrant initially determined
that since the reason for the changes to the broad-based indexes was due to the
implementation of the Tailored Shareholder Report (TSR) Rule and the updated
definition of a broad-based index, rather than a decision by the Funds,
disclosure for the change was not required. Through further inquiries, it was
determined that the disclosure was a required disclosure in accordance with the
TSR Rule.

10. XBRL data tagging

COMMENT:

Reference
U.S. Securities and Exchange Commission ADI 2024-14 (“ADI”). Under the ADI item
7, note that broad-based and additional indexes need to be tagged with separate
tags.

RESPONSE:

This has been discussed with the
third-party filing agent and the change will be made on all future Tailored
Shareholder Reports’ filings beginning with the January 31, 2025 semi-annual
report.

11. Performance information

COMMENT:

Reference
27A(d), Instruction 15 of the N-1A instruction pertaining to availability of
updated performance information. Please direct shareholders where they can find
the information.

RESPONSE:

This change will be made on all future
Tailored Shareholder Reports’ filings beginning with the January 31, 2025
semi-annual report.

13. Website disclosures

COMMENT:

Please
update the link for the proxy voting link on the fund website for the 2024
proxy period.

RESPONSE:

The proxy voting links on the Funds’
website have been updated with 2024 information.

5

The following comments and responses relate to the financial
statements

14. Concentration of credit risk

COMMENT:

Please
reference FASB ASC 825-10-50 and AICPA meeting minutes from January 21, 2020. Funds
are allowed to categorize holdings by Industry, Country, or State. Viking
Mutual Funds has its bonds categorized by Industry. Please depict credit risk
and disclose significant concentration by utilizing a chart of portfolio
breakout noting no territories (for example) and that the bonds consist of all Montana,
North Dakota, Kansas, Maine, Nebraska, or Oklahoma municipal bonds.

RESPONSE: All municipal bond funds in
the Viking Mutual Funds Trust are 100% invested in issuers of their respective
states. A disclosure will be added for each Fund to future Forms N-CSR filings beginning
with the January 31, 2025 financial statements.

15. Consistent disclosures of investment objective

COMMENT:

Under
Note 1 of the financial statements, there is inconsistent disclosures of
investment objectives between prospectus and financial statements. Please
update these so they are consistent between the prospectus and financial
statements for Integrity Dividend Harvest Fund, Integrity Dividend Summit Fund
and Integrity Mid-North American Resources Fund.

RESPONSE:

The revision to Note 1 of the
financial statements will be included in all future filings beginning with the
January 31, 2025 semi-annual report for Integrity Dividend Harvest Fund,
Integrity Dividend Summit Fund and Integrity Mid-North American Resources Fund.

The following comments and responses consist of related party
disclosures

16. Management fees

COMMENT:

Please
disclose how often the management fees are paid.

RESPONSE:

Management fees are paid on a monthly
basis. This disclosure will be included in the financial statement footnotes
for all future filings beginning with the January 31, 2025 semi-annual report for
The Integrity Funds and Viking Mutual Funds.

17. Sub-advisers

COMMENT:

Reference
Form N-CEN B15. Should the box for that item have been checked indicating
reliance on an exemptive order such as the Manager of Managers exemptive order.
Also, the disclosure for the sub-adviser should disclose that it is paid by the
adviser. Disclose this and the rate paid to the sub-adviser.

RESPONSE:

The Registrant has determined that the
box should remain unchecked for Item B.15. of Form N-CEN. Although the
Registrant has a Manager of Managers exemptive order in place, it has not been
relied upon since 2009. The disclosure stating that Sub-advisers are paid by
the Adviser, including the rate paid to the Sub-Advisers, will be included in
the financial statement footnotes for all future filings beginning with the
January 31, 2025 semi-annual report for The Integrity Funds. This disclosure is
currently included in the Registrant’s prospectus dated November 30, 2024.

6

18. Weighted average calculation

COMMENT:

Reference
FASB ASC 820-10-50-2. In Note 3 of the notes to financial statements, please
disclose how the weighted average was calculated.

RESPONSE:

Additional disclosures related to the
calculation of weighted average included i