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www.dechert.com

April 22, 2020

Via EDGAR

Alison White, Esq.

Senior Counsel

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

 Re: Praxis Mutual Funds, File Nos. 033-69724 and 811-08056

Post-Effective Amendment No. 56

Dear Ms. White:

On behalf of the Praxis Mutual Funds (the “Registrant”)
and each of its series (a “Fund”), I am responding to the comments you provided to me via telephone on April 1, 2020,
regarding post-effective amendment no. 56 to the Registrant’s registration statement filed on Form N-1A pursuant to Rule
485(a) under the Securities Act of 1933, as amended.

 1. Comment: All Funds. Significant market events have occurred since this post-effective amendment was filed as a result
of the COVID19 pandemic. Please consider whether the Funds’ disclosures, including risk disclosures, should be revised based
on how these events are affecting both debt and equity markets. If the Registrant believes that no additional disclosure is warranted,
please explain supplementally why not.

Response: COVID19-related
related risk disclosure will be added.

 2. Comment: All Funds. Please provide a completed fee table and expense example for each Fund prior to the contemplated
effective date.

Response: Completed fee tables, as they will appear
in the Registrant’s 485(b) filing, are included as an exhibit to this letter.

 3. Comment: All Funds other than Genesis Portfolios. Footnote 1 to the Fees and Expenses table indicates that “Other
Expenses” include indirect expenses of securities of other mutual funds held by the Fund, if any. If those expenses exceed
1 basis point, please add a separate “acquired fund fees and expenses” line item to the table. In addition, if investments
in other mutual funds is a principal investment strategy, please add principal investment strategy and risk disclosures.

Response: Management has reviewed the acquired
fund fees for all Funds and has concluded that the indirect expenses of securities of other mutual funds held by each Fund (excluding
the Genesis Portfolios) is less than 1 basis point for the fiscal year 2019. With the exception of the Genesis Portfolios, investments
in other mutual funds is not a principal investment strategy for any Fund.

 4. Comment: All Funds. In the Principal Investment Risks section for each Fund, please place each principal risk in its
own paragraph, with a separate heading and/or a bullet, rather than discussing multiple risks within a combined paragraph.

    U.S. Securities and Exchange Commission

04/21/20

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Response: The requested change will be made.

 5. Comment: Impact Bond Fund. In the Principal Investment Risks section for the Fund, please add principal risk disclosure
for government related securities such as government sponsored enterprises (GSEs).

Response: The requested change will be made.

 6. Comment: Praxis International Index Fund, Praxis Value Index Fund, Praxis Growth Index Fund and Praxis Value Index Fund
(the “Index Funds”). Please disclose the rebalancing and reconstitution process the Fund’s benchmark index including
frequency and the number or range of companies in the index; also, if any of these Funds uses derivatives to track its index, please
revise the principal investment strategies and risk disclosure to include use of those derivatives.

Response: The requested disclosure will be added
to the statutory section of the prospectus. The Registrant does not regard this level of detail about the indexes as necessary
or appropriate for the summary section. None of the Funds currently uses derivatives to track its benchmark index.

 7. Comment: All Index Funds. The Principal Investment Strategies section for each Index Fund provides that, under normal
circumstances, the Fund invests at least 80% of the value of its assets “in securities of, and investments related to”
issuers in the Fund’s benchmark index and, for the International Index Fund, that investments related to the benchmark index
include ADRs. Please revise the disclosure to clarify what if anything each Index Fund invests in that are treated as investments
related to issuers in the Fund’s benchmark index.

Response: The International Index Fund currently
uses ADRs for this purpose. The other Index Funds do not use other investments for this purpose. In light of the comment, the disclosure
for the International Index Fund will be revised as follows (deletions stricken, additions underlined):

“Under normal circumstances, the Fund invests at
least 80 percent of the value of its assets in securities of, and investments related to, issuers in the Fund’s benchmark
index. Typically, the Fund invests substantially more than 80 percent of the value of its assets in such securities and investments.
Investments related to the benchmark index include in which the Fund invests consist of American Depositary
Receipts (ADRs), which are equity securities that represent shares of foreign companies in the index.”

The disclosure for the other Index Funds will be revised
as follows (deletions stricken, additions underlined):

“Under normal circumstances, the Fund invests at
least 80 percent of the value of its assets in securities of, and investments related to, issuers in the Fund’s benchmark
index. Typically, the Fund invests substantially more than 80 percent of the value of its assets in such securities
of issuers in its benchmark index.”

 8. Comment: Please explain the basis for the Registrant’s view that use of “index” in the names of the
Index Funds is appropriate.

    U.S. Securities and Exchange Commission

04/21/20

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Response: The defining characteristic of an index
fund is that it seeks to track the performance of its benchmark index, and each Index Fund (for purposes of this response, also
referred to as a “Fund”) does just that, as reflected in its name. As further discussed below, in our view:

 • Each Fund’s name is consistent with Section 35(d) of the Investment Company Act and Rule 35d-1 thereunder.

 • Each Fund’s name conveys its intention to seek to reflect the performance of its benchmark index and is therefore helpful
to investors and consistent with its principal investment strategies.

 • Revising a Fund’s name to modify or omit the term “index” is sub-optimal. Adding “optimized”
or another modifier before “index” in each Fund’s name would add complexity and length to the name. Removing
“index” from each Fund’s name would remove a helpful signal to investors about each Fund’s principal investment
strategies.

Principal Investment Strategies:
The Funds have substantively identical disclosures about their principal investment strategies, with variations attributable to
the particular benchmark index each seeks to track and the specific types of securities in which each invests. For example, the
Praxis Value Index Fund has the following Principal Investment Strategies disclosure (emphasis added):

The Fund invests primarily in U.S. equity
securities and seeks to reflect the performance of the U.S. large capitalization value equities market, as measured
by the S&P 500 Value Index, its benchmark index. Under normal circumstances, the Fund invests at least
80 percent of the value of its assets in securities of, and investments related to, issuers in the Fund’s benchmark
index. Typically, the Fund invests substantially more than 80 percent of the value of its assets in such securities. The
benchmark index consists of those stocks in the S&P 500 Index determined to exhibit the strongest “value” characteristics
based on book value to price, earnings to price and sales to price ratios. The Fund seeks to invest in companies aligned with the
Stewardship Investing core values, as discussed below. In addition, the Adviser uses optimization techniques, including ESG factors,
to select securities according to their contribution to the Fund’s overall objective, while seeking to replicate the characteristics
of the index, including risk and return characteristics.

Legal Basis for Name and Principal
Investment Strategies: Each Fund’s name and 80% policy comply with Section 35(d) and Rule 35d-1. Section 35(d) provides
in pertinent part that is unlawful for any registered investment company to adopt as part of its name any word that the Commission
finds materially misleading or deceptive and authorizes the Commission to define such names by rule, regulation or order. Rule
35d-1 provides in pertinent part that a name suggesting a registered investment company focuses its investments in a particular
type of investment would be materially deceptive and misleading unless it has adopted a policy to invest, under normal circumstances,
at least 80% of the value of its net assets, plus the amount of any borrowings for investment purposes, in the particular type
of investment suggested by the name. Because each Fund uses “index” in its name, it has adopted a policy to invest,
under normal circumstances, at least 80% of the value of its net assets plus borrowings for investment purposes (“assets”)
in the particular type of investments suggested by its name, in this case, constituents of its benchmark index. This 80% policy
meets the requirements of Rule 35d-1.

    U.S. Securities and Exchange Commission

04/21/20

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Each Fund’s name and 80% policy
also comply with published Commission guidance relating to index funds. In the release adopting Rule 35d-1, the Commission stated:
“Index Funds, for example, generally would be expected to invest more than 80% of their assets in investments connoted by
the applicable index.” In accordance with this guidance, each Fund consistently invests substantially more than 80% of its
assets in securities of constituents of its benchmark index. As of December 31, 2019, for example, the percentage of the value
of each Fund’s assets that was invested in securities (in the case of the International Index Fund, including ADRs) of issuers
in the Fund’s benchmark index, was as follows:

    Fund Name
    Percentage

    Praxis International Index Fund
    98.30

    Praxis Value Index Fund
    97.20

    Praxis Growth Index Fund
    97.85

    Praxis Small Cap Index Fund
    98.84

Each Fund’s name conveys its intention to seek
to track the performance of its benchmark index and is therefore helpful to investors and consistent
with its principal investment strategies. Each Fund’s Principal Investment Strategies section provides additional
detail about how the Fund seeks to track the performance of its benchmark index, which complements
its 80% policy and is consistent with its use of “index” in its name. This disclosure makes clear that while the Fund
does not seek to hold every constituent of its benchmark index, it invests substantially all of its assets index constituents
(or related securities) and seeks to replicate the performance of the index. This complies fully with Form N-1A, the Investment
Company Act, applicable rules and published guidance.

Each Fund’s name is
consistent with industry practices and investor expectations. We are not aware of any legal requirement for a mutual fund that
uses “index” in its name to adopt a policy to hold every constituent of the applicable index and observe that such
a policy, except in certain narrow circumstances, can be inefficient and impractical. In our experience, while some index-based
mutual funds seek to match or replicate the entire composition of the indexes whose performance they seek to track
(that is, to hold all of the index constituents in the same or approximately the same proportion as the index), many index-based
mutual funds, like the Funds, seek to track or replicate the performance of their indexes by holding an optimized
sub-set of components of the index. Constructing an index-based portfolio in this manner is commonly described as using “optimization”
or “sampling.” Optimization/sampling is widely used by index funds because holding every index component is inefficient,
and for certain asset classes and indexes, impracticable. Given the widespread use optimization/sampling by index funds, we believe
its use is consistent with investor expectations for mutual funds that hold themselves out as index funds. With regard to the Funds
in particular, those expectations are reinforced with clear and conspicuous disclosure in the Funds’ Principal Investment
Strategies sections.

Index-based mutual funds following both approaches routinely
use “index” in their names. Inclusion of more specific terms, such as “optimized index” with regard to
the former, or “replicated index” with regard to the latter, are less common and neither is legally required.

Application of ESG factors
does not alter the above conclusions. Like any other index-based mutual fund using an optimization/sampling strategy, each
Fund is accurately described as an index fund. As is common for index funds, each Fund’s optimization process is used to
construct a portfolio that seeks to replicate the performance of the applicable benchmark index. Application of ESG factors as
a component of each Fund’s optimization process, a process that is used to construct portfolios designed to track its benchmark
index, does not alter a Fund’s character as an index fund any more than a non-ESG motivated sampling method used by another
fund complex would disqualify its optimized index funds from identifying themselves as index funds.

    U.S. Securities and Exchange Commission

04/21/20

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In this regard, construction
of the Fund’s portfolio is consistent with any other index-based mutual fund that utilizes an optimization or sampling strategy
in that a proprietary method is used to build a portfolio from a sub-set of the index constituents that is designed to closely
track the performance of the index. The fact that a Fund excludes certain index constituents before applying the optimization
methodology to build the portfolio to track the performance of the index does not in any way imply that this Fund is not aptly
described as an index fund.

Changing a Fund’s name to modify or omit “index”
would be less helpful to investors than continuing to use the existing name. Adding “optimized” or another modifier
before “index” would add complexity and length to each Fund’s name, while removing “index” would
remove a helpful signal to investors about each Fund’s principal investment strategies. Accordingly, in the Registrant’s
view, neither change is preferable to the existing name of each Fund. In addition, making any type of change to a Fund’s
name would require deployment of resources to inform investors and financial intermediaries about the change. The Registrant believes
that would be a challenging messaging campaign since Fund shareholders and intermediaries understand the investment strategies
for these Funds and are familiar with their current names, and that any of the suggested name changes would be perceived, at best,
as a neutral event.

For these reasons, we respectfully submit that the existing
name of each Fund is consistent with applicable legal requirements, and accordingly, that the existing name of each Fund is appropriate.

 9. Comment: Small Cap Index Fund and Genesis Portfolios. The SEC staff believes that recoupment provisions like those disclosed
in footnote 2 to the Annual Fund Operating Expenses table for the Small Cap Index Fund and the Genesis Portfolios should not extend
beyond 3 years from the date on which, or end of the month in which, the waiver or reimbursement subject to the recoupment occurred.
Please revise the applicable expense limitation agreement and footnote disclosure accordingly, or confirm that a FAS 5 assessment
was completed with a conclusion that recoupment is not probable.

Response: The requested change will be made. The
expense limitation agreement and footnote discl