SecProbe.io

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                                                    Aaron Remorenko
                                                    PFPC Inc.
                                                    99 High Street, 27th Floor
                                                    Boston, Massachusetts 02110
                                                    (617) 338-4426

                                                    March 23, 2005

VIA EDGAR
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Securities and Exchange Commission
Division of Investment Management, Room 5501
450 Fifth Street, NW
Washington, DC 20549-0505
Attention:  Mr. James O'Connor

Re:  ABN AMRO Funds (the "Registrant" or the "Trust")
     1933 Act No. 33-68666
     1940 Act No. 811-8004
     Post-Effective Amendment No. 55
     -------------------------------

Dear Mr. O'Connor:

     This letter is in response to our telephone conference on February 9, 2005
regarding the Registrant's Post-Effective Amendment No. 55 to its Registration
Statement on Form N-1A filed with the Commission on December 29, 2004 pursuant
to Rule 485(a) under the Securities Act of 1933, as amended (the "Securities
Act"). The following sets forth the comments received during the telephone
conference and the Registrant's responses to them. All page references are for
the Class N Prospectus and Statement of Additional Information included in
Post-Effective Amendment No. 56 filed with the Commission on February 25, 2005
pursuant to Rule 485(b) under the Securities Act.

PROSPECTUS

1. Calculating Share Price (Pages 42-43)

     Comment:  Please clarify the situations in which the Trust fair values the
               Funds' securities and please explain how the Board of Trustees of
               the Trust monitors fair value pricing of the Funds' securities.

     Response: The disclosure has been revised to provide examples of
               circumstances when a security held by the Funds may be fair
               valued. These circumstances include when trading in the security
               is suspended, the exchange or market on which the security is

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               traded closes early or the trading volume in the security is
               limited, calling into question the reliability of market
               quotations. In addition, disclosure was added that the Board of
               Trustees receives a report of any actions taken under the Funds'
               fair valuation procedures.

2. Short-Term and Excessive Trading (Pages 43-44)

     Comment:  Please disclose whether the Trust knowingly accommodates market
               timing or frequent trading.

     Response: The disclosure was revised to state that the each Fund
               discourages and does not knowingly accommodate short-term and
               excessive trading.

3. Redemption Fees (Pages 44-45)

     Comment:  Please clarify how the exception for "certain types of accounts
               held through intermediaries" discussed in the fourth paragraph of
               this section differs from the situations discussed in the
               preceding paragraph.

     Response: The reference to "certain types of accounts held through
               intermediaries" in the fourth paragraph was deleted.

4. Portfolio Holdings (Page 28)

     Comment:  Please add language directing shareholders to the Statement of
               Additional Information for a description of the Trust's policies
               and procedures with respect to disclosure of each Fund's
               portfolio holdings.

     Response: This information was included in the prospectuses under the
               heading "Portfolio Holdings."

STATEMENT OF ADDITIONAL INFORMATION

1. Disclosure of Portfolio Holdings (Page 86-87)

     Comment:  Please disclose who may authorize the disclosure of portfolio
               holdings information as an exception to the Trust's policies and
               procedures.

     Response: The disclosure has been revised to state that disclosure of the
               Funds' portfolio holdings information as an exception to the

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               Trust's policies and procedures must be approved by the Chief
               Compliance Officer or the Chief Executive Officer of the Trust.

     Comment:  Please disclose whether the Trust monitors the use of portfolio
               holdings information after it is disclosed.

     Response: Disclosure has been added that the Chief Compliance Officer or
               his designee is responsible for monitoring compliance with the
               Trust's procedures with respect to disclosure of portfolio
               holdings.

     Comment:  Please disclose whether the Trust receives any compensation for
               the disclosure of portfolio holdings information.

     Response: Disclosure has been added to state that no compensation or other
               consideration is received by the Trust or any affiliate of the
               Trust for disclosure of portfolio holdings information.

     Comment:  Please identify who receives information about the Funds'
               portfolio holdings prior the public disclosure of such
               information.

     Response: A list of the entities that receive the Funds' portfolio holdings
               information prior to its public disclosure as well as the
               frequency and the lag time between the date of the information
               and the date it is disclosed was added to the Statement of
               Additional Information.

     All changes have been incorporated into Post-Effective Amendment No. 56
filed with the Commission on February 25, 2005 pursuant to Rule 485(b) under the
Securities Act.

Sincerely,

/s/ Aaron Remorenko

Aaron Remorenko

cc:  Gerald Dillenburg
     Cathy O'Kelly, Esq.
     Gail Hanson, Esq.

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March 23, 2005

VIA EDGAR
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Mr. James O'Connor
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549-0506

RE:      ABN AMRO Funds (the "Registrant")
         (File Nos. 033-68666 and 811-08004)

Dear Mr. O'Connor:

In connection with a response being made on behalf of the Registrant to comments
that you provided with respect to Post-Effective Amendment No. 55 to the
Registrant's registration statement on Form N-1A under the Securities Act of
1933 (the "Filing") as filed with the Securities and Exchange Commission on
December 29, 2004, the Registrant hereby acknowledges that:

    -    The Registrant is responsible for the adequacy and the accuracy of the
         disclosure in the Filings;
    -    Comments of the staff of the Securities and Exchange Commission ("SEC
         Staff") or changes to disclosure in response to SEC Staff comments in
         the Filing reviewed by SEC Staff do not foreclose the Securities and
         Exchange Commission from taking any action with respect to the Filing;
         and
    -    The Registrant may not assert SEC Staff comments as a defense in any
         proceeding initiated by the Securities and Exchange Commission or any
         person under the federal securities laws.

                                          Sincerely,

                                          /s/ Kenneth C. Anderson

                                          Kenneth C. Anderson
                                          President and Chief Executive Officer

cc:      Gerald F. Dillenburg
         Cathy G. O'Kelly, Esq.
         Gail A. Hanson, Esq.

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