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CORRESP
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CORRESPONDENCE LETTER

[ROPES & GRAY LOGO]

ROPES & GRAY LLP

ONE INTERNATIONAL PLACE   BOSTON, MA 02110-2624   617-951-7000   F 617-951-7050

BOSTON   NEW YORK   SAN FRANCISCO   WASHINGTON, DC

December 23, 2004                                          Leigh R. Fraser
                                                           (617) 951-7485
                                                           lfraser@ropesgray.com

Securities and Exchange Commission
Division of Investment Management
450 Fifth Street, N.W.
Washington, D.C. 20549

Attn: Kim Browning, Esq.

     Re:  Schroder Enhanced Income Fund (the "Fund"), a series of Schroder
          Series Trust (the "Trust"), Post-Effective Amendment No. 21 to the
          Trust's Registration Statement on Form N-1A under the Securities Act
          of 1933 and Post-Effective Amendment No. 23 to the Trust's
          Registration Statement on Form N-1A under the Investment Company Act
          of 1940 (the "Registration Statement"), filed with the U.S. Securities
          and Exchange Commission (the "Commission") on October 28, 2004
          (Securities Act of 1933 File No. 33-65632 and Investment Company Act
          of 1940 File No. 811-7840)

Dear Ms. Browning:

     This letter sets forth the Fund's responses to comments you provided to my
colleague Jessica O'Mary telephonically on December 9, 2004. For convenience of
reference, I have summarized below the text of each comment in bold before each
response; the Trust's responses follow in normal typeface. In addition, enclosed
with this letter is a copy of each of the Investor Shares Prospectus, Advisor
Shares Prospectus and Statement of Additional Information, marked to reflect
changes that will be made in response to the comments.

     PROSPECTUS(1)

     (1) PLEASE MAKE THE REQUESTED "TANDY" LETTER STATEMENTS IN YOUR LETTER TO
US.

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(1)  These comments apply to both the Advisor and Investor Share prospectuses.

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                                       -2-                     December 23, 2004

     On behalf of the Trust, we acknowledge that:

     (a) the Trust is responsible for the adequacy and accuracy of the
disclosure in the Registration Statement;

     (b) Commission staff comments or changes to disclosure in response to
Commission staff comments in the filings reviewed by the staff do not foreclose
the Commission from taking any action with respect to a filing; and

     (c) the Trust may not assert Commission staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

     (2) YOU QUESTIONED WHETHER SUMMARY INFORMATION ON THE COVER PAGE WAS
APPROPRIATE BUT INDICATED THAT YOU MIGHT WITHDRAW THIS COMMENT.

     The language has not been revised, in light of the Staff's continuing
review. The Trust would prefer to leave this language on the cover page.

     (3) PLEASE EXPLAIN THE DEFINITION OF "ENHANCED" IN THE NAME OF THE FUND.

     The use of the term "Enhanced" in the name of the Fund is intended to
reflect the somewhat broader investment mandate of the Fund than that of many
other very short duration income funds. The Fund seeks not only current income,
but more generally high total return, of which current income is an element.
Language in the Prospectus making clear that the adviser may trade the Fund's
portfolio securities to take advantage of temporary pricing disparities has been
moved to the Principal Investment Strategies section of the Prospectus, and
additional language intended to emphasize the Fund's total return orientation
has been provided.

     (4) PLEASE EXPLAIN WHY, FOR A FUND THAT INVESTS IN FIXED INCOME SECURITIES,
TOTAL RETURN IS A PRINCIPAL INVESTMENT OBJECTIVE.

     See response to comment (3) above.

     (5) PLEASE DO NOT USE THE NAME OF THE INVESTMENT ADVISER (OR SUB-ADVISER)
PRIOR TO ITEM 4 DISCLOSURE. INSTEAD, REFER TO THE ADVISER AS SUCH.

     The requested changes will be made.

     (6) PLEASE EXPLAIN, IN RELATION TO THE INVESTMENT OBJECTIVES, WHERE CAPITAL
APPRECIATION WILL COME FROM AND HOW THE INSTRUMENTS WILL PRODUCE THE INVESTMENT
OBJECTIVE.

     See response to comment (3) above.

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                                       -3-                     December 23, 2004

     (7) YOU STATE THAT THE FUND MAY INVEST IN U.S. DOLLAR-DENOMINATED FIXED
INCOME SECURITIES. PLEASE SPECIFY WHAT INSTRUMENTS YOU MEAN (E.G., ADRS) AND
PROVIDE SPECIFIC RELATED RISKS FOR THOSE INSTRUMENTS.

     The types of U.S. dollar-denominated fixed income securities in which the
Fund may invest are listed in the bullet points under "Principal Investment
Strategies." Risks of investing in U.S. dollar-denominated foreign securities
are described under "Principal Risks of Investing in the Fund." The Fund does
not plan to invest in American Depositary Receipts.

     (8) ON PAGE 2, PLEASE REMOVE THE PHRASE "EXPECTS UNDER CURRENT MARKET
CONDITIONS" BECAUSE AT THE TIME OF PRINTING THIS STATEMENT WILL BE HISTORICAL.
ONE POSSIBLE SOLUTION IS TO PUT IN A DATE.

     The requested change will be made.

     (9) PLEASE CLARIFY WHETHER THE FUND WILL USE DERIVATIVE INSTRUMENTS FOR
SPECULATIVE PURPOSES, BEYOND HEDGING. PLEASE LIST ALL OF THE DERIVATIVE
INSTRUMENTS THE FUND WILL INVEST IN AND INCLUDE THE APPROPRIATE DISCLOSURE UNDER
ITEM 2 AND ITEM 4 OF FORM N-1A.

     The language has been revised.

     (10) PLEASE AVOID THE PASSIVE VOICE.

     The requested changes will be made.

     (11) PLEASE REMOVE THE DISCLOSURE REGARDING THE FUND'S DOLLAR WEIGHTED
AVERAGE BECAUSE THERE IS CURRENTLY NO ACTUAL RATING. THIS DISCLOSURE CAN BE
INCLUDED IN FUTURE FILINGS, BUT WILL NEED TO INCLUDE A PIE CHART OR OTHER GRAPH
SHOWING THE ACTUAL BREAKDOWN OF HOLDINGS.

     The language has been revised.

     (12) PLEASE DISCLOSE, IN THE FOREIGN INVESTMENT RISK, WHETHER THE FUND
INTENDS TO INVEST IN EMERGING MARKETS. IF NOT, THEN REPRESENT THAT THE FUND WILL
NOT DO SO IN YOUR LETTER TO US.

     The Fund does not intend to invest in emerging markets.

     (13) PLEASE DISCLOSE IF THE ADVISER'S FEE IS NOT APPLIED EQUALLY TO THE
ADVISOR AND INVESTOR SHARES BOTH PRE-WAIVER AND POST-WAIVER. IF IT IS APPLIED
EQUALLY, PLEASE REPRESENT THIS TO US.

     The fee is applied equally to the Advisor and Investor Shares both pre- and
post-waiver.

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                                       -4-                     December 23, 2004

     (14) IN REGARDS TO THE FEE TABLE, PLEASE NOTE THAT INCLUSION OF THIS
NEGATIVE INFORMATION IS OPTIONAL.

     The Trust will retain the current formulation.

     (15) PLEASE DISCLOSE IF THE ADVISER HAS ANY RECOUPMENT RIGHTS FOR ITS FEE,
AND IF THERE ARE NO SUCH RIGHTS, MAKE A REPRESENTATION IN YOUR LETTER TO US.

     The adviser does not have such recoupment rights.

     (16) CONFIRM IN YOUR LETTER TO US THAT THE CALCULATION OF ONE-YEAR COSTS IS
NET, AND THREE-YEAR COSTS IS GROSS, OF ANY FEE WAIVER.

     The calculation of one-year expenses is net, and the calculation of
three-year expenses is gross, of any fee waiver.

     (17) IN REGARDS TO THE DISCLOSURE OF A 400% TURNOVER RATE, THE STAFF
CONSIDERS FREQUENT AND ACTIVE TRADING A PRINCIPAL STRATEGY. PLEASE INCLUDE THIS
IN THE PRINCIPAL STRATEGIES AND RISK DISCLOSURES.

     The requested change will be made.

     (18) PLEASE CLARIFY THE ACTIVITIES OF STEVEN LEAR AND THE OTHER PORTFOLIO
MANAGERS FOR THE LAST FIVE YEARS.

     The requested change will be made.

     (19) IN "HOW THE FUND'S SHARES ARE PRICED," PLEASE EXPLAIN THE AUTHORITY
FOR THE STATEMENT "THEY MAY BE VALUED AS OF A TIME UP TO 15 MINUTES AFTER THE
CLOSE OF TRADING," WHY THIS IS THE CASE, AND THE APPLICABLE PROCEDURE.

     This language will be deleted.

     (20) ALSO IN "HOW THE FUND'S SHARES ARE PRICED," PLEASE REPLACE THE TERM
"NOT ASCERTAINABLE" WITH "NOT READILY AVAILABLE."

     The requested change will be made.

     (21) PLEASE CLARIFY WHETHER FAIR VALUES ARE DETERMINED BY THE ADVISER.

     Fair values are determined by the adviser. Language to this effect will be
added under "How the Fund's Shares are Priced."

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                                       -5-                     December 23, 2004

     (22) IN THE FAIR VALUE DISCLOSURE, YOU MAKE THE STATEMENT "CERTAIN
SECURITIES OR INVESTMENTS FOR WHICH MARKET QUOTATIONS ARE NOT READILY AVAILABLE
MAY BE VALUED. . ." PLEASE CONFIRM THAT IT IS AN ACCURATE STATEMENT AND THAT
ONLY SOME AND NOT ALL SECURITIES ARE SUBJECT TO THIS PROCEDURE.

     We have confirmed with the adviser that this statement is accurate.

     (23) IT APPEARS THAT THE FUND WILL INVEST IN MONEY MARKETS. PLEASE CLARIFY
HOW THE FUND WILL VALUE, AND THE APPLICABLE PROCEDURE FOR VALUING, SECURITIES
THAT MATURE IN 60 DAYS OR LESS.

     Please refer to "How the Fund's Shares Are Priced," where the Prospectus
states that short-term investments that mature within 60 days are valued using
amortized cost, a form of fair valuation, pursuant to procedures adopted by the
Board of Trustees.

     (24) IN "HOW TO BUY SHARES," PLEASE CLARIFY THAT ORDERS MUST BE RECEIVED BY
THE FUND IN "GOOD ORDER," AND EXPLAIN HOW THE INVESTOR CAN MEET THIS
REQUIREMENT.

     The requested clarification will be made.

     (25) ALSO IN "HOW TO BUY SHARES," IN REGARDS TO THE STATEMENT "IN ORDER FOR
YOU TO RECEIVE THE FUND'S NEXT DETERMINED NET ASSET VALUE. . .", PLEASE CLARIFY
WHEN THE ORDER MUST BE RECEIVED (I.E. BY 4 PM EST).

     The requested clarification will be made.

     (26) IN "HOW TO BUY SHARES," YOU STATE THAT INVESTORS IN THE FUND SHOULD
ANTICIPATE COSTS RELATED TO SHORT TERM TRADING. PLEASE CLARIFY WHY THERE IS NO
REDEMPTION FEE TO DEFRAY THESE COSTS AND WHETHER THE BOARD CONTEMPLATED A
REDEMPTION FEE.

     The Fund is managed in a manner consistent with the expectation that
investors will use the Fund as a cash substitute and that the Fund will be
subject to frequent purchase and sale activity. As a result, the Trust believes
that a redemption fee would be inconsistent with this use and thus
inappropriate. As described in the Prospectus, the Fund will incur costs and
expenses related to short-term trading in its shares. However, the Trust expects
that these costs and expenses will not be in an amount that is inconsistent with
the short-term nature of the Fund or its likely use as a cash substitute, and
that the costs and expenses will be in line with expectations of investors in
pooled cash vehicles generally.

     (27) PLEASE INCLUDE A DEFINITION OF "EXCESSIVE TRADING."

     The adviser believes that the universe of activity that is likely to be
seen as "excessive" in a mutual fund like the Fund - with a very short duration
and likely used by investors as a cash substitute - is quite limited. As a
result, the Trust would prefer to leave the term undefined but to

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                                       -6-                     December 23, 2004

retain the flexibility to terminate accounts through which potentially abusive
trading might be occurring. As this time, the adviser does not believe such
activity is likely.

     (28) PLEASE PROVIDE A FOOTNOTE TO THE FEE TABLE IF THERE IS A FEE FOR BANK
WIRES AND IF THERE IS NO SUCH FEE THEN PROVIDE A REPRESENTATION TO US TO THAT
EFFECT.

     There is no fee for bank wires.

     (29) PLEASE CLARIFY WHETHER THE FUND WILL ACCEPT PAY IN-KIND SECURITIES
FROM ANOTHER FUND COMPLEX. IF SO, PLEASE ADD DISCLOSURE AND ADD A RISK FACTOR
REGARDING DILUTION OF THE FUND FOR ERRONEOUS VALUATION. IF NOT, PLEASE PROVIDE A
RELATED REPRESENTATION TO US.

     Language will be added regarding this issue under "How to Buy Shares -
Purchases in-kind."

     (30) PLEASE CHANGE THE PHRASE "UNUSUAL CIRCUMSTANCES" UNDER "HOW TO SELL
SHARES" TO "EMERGENCIES."

     The requested change will be made.

     STATEMENT OF ADDITIONAL INFORMATION

     (31) PLEASE CONFIRM IN YOUR LETTER TO US, AND IF NECESSARY REVISE THE
DISCLOSURE, THAT ALL THE PRINCIPAL INVESTMENT STRATEGIES ON PAGE B-2 ARE
INCLUDED IN THE PROSPECTUS ITEM 2 AND ITEM 4 DISCLOSURE.

     We confirm that all the Principal Investment Strategies on page B-2 are
included in the Prospectus item 2 and item 4 disclosure.

     (32) IN THE DISCUSSION OF SHORT SALES ON PAGE B-16, PLEASE EXPLAIN HOW THE
FUND WILL COVER SHORT SALES.

     The requested change will be made.

     (33) PLEASE CHANGE THE HEADING OF "MISCELLANEOUS INVESTMENTS, INVESTMENT
PRACTICES AND RISKS" TO "NON-PRINCIPAL INVESTMENTS, INVESTMENT PRACTICES AND
RISKS."

     The requested change will be made.

     (34) PLEASE REMOVE INVESTMENT RESTRICTION 4(II) ON PAGE B-18 BECAUSE IT
APPLIES TO TAX-FREE FUNDS.

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                                       -7-                     December 23, 2004

     This investment restriction is a general industry concentration requirement
and does not relate only to tax-free funds; accordingly, the Trust believes that
it would be inappropriate to delete the restriction.

     (35) PLEASE ADD DISCLOSURE EXPLAINING THE PERCENTAGE OF TOTAL ASSETS THAT
MAY BE LOANED IN REPURCHASE AGREEMENTS AND PORTFOLIO LENDING. (PLEASE NOTE THAT
THIS CAN BE ADDED TO THE TEXT AFTER THE INVESTMENT RESTRICTIONS).

     Disclosure stating that the aggregate market value of the Fund's portfolio
securities loaned will not exceed one-third of the total assets of the Fund is
included on page B-16 under "Loans of Fund Portfolio Securities." The Fund does
not have a percentage limit on its use of repurchase agreements.

     (36) ON PAGE B-19, PLEASE ADD POLICIES REGARDING LENDING, ACQUIRING CONTROL
OF OTHER FUNDS, AND ON SHORT SALES.

     An investment restriction regarding lending is included (see #5 under
"Investment Restrictions"). We do not believe that investment restrictions
regarding acquiring control of other funds and short sales are required.

     (37) IN THE PERFORMANCE INFORMATION DISCUSSION, YOU SUGGEST IN A FOOTNOTE
THAT NOT ALL ACCOUNTS WILL BE INCLUDED. IF NOT ALL ACCOUNTS ARE INCLUDED, PLEASE
MAKE A REPRESENTATION TO US THAT THE EXCLUSION OF ACCOUNTS WILL NOT RENDER THE
DISCLOSURE MISLEADING. OTHERWISE, PLEASE CLARIFY THE DISCLOSURE.

     This language will be clarified.

     (38) IN THE CHART SHOWING THE PERFORMANCE OF THE SCHRODERS COMPOSITE,
PLEASE CLARIFY THE AUTHORITY FOR DEDUCTING NET EXPENSES.

     The Net Expenses of the Fund are being used as a proxy for the actual
expenses of the accounts included in the Schroders Composite. As described in
the Statement of Additional Information, the Net Expenses for the Fund are in
all cases higher than the actual historical expenses of each of the accounts in
the Schroders Composite for all periods shown (except that some, though not all,
share classes offered by unregistered funds to certain investors had higher
fees, but not any unregistered funds as a whole). As a result, if the actual
expenses of the accounts (as opposed to the Net Expenses of the Fund) had been
deducted, the performance of the Schroders Composite would have been better. The
Trust believes that the Net Expenses number provides more meaningful disclosure
to investors than either gross performance numbers or performance numbers for
the other Schroders accounts (which, as noted, are generally higher than the Net
Expenses of the Fund).

     (39) PLEASE PROVIDE MORE DISCLOSURE RELATING TO "BROKERAGE ALLOCATION" ON
PAGE B-32, INCLUDING HOW THE FUND SELECTS BROKERAGE AND THE BROKERAGE SELECTION
PROCESS.

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                                       -8-                     December 23, 2004

     The requested change will be made.

                                   * * * * * *

     I hope that the foregoing is responsive to your comments. If you have any
questions please call me at (617) 951-7485 or my colleague Timothy W. Diggins at
(617) 951-7389. Thank you for your efforts in reviewing the Registration
Statement.

Very truly yours,

/s/ L