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CORRESP
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CORRESP

 July 15, 2022

 Securities and Exchange Commission

100 F Street NE

 Washington, D.C. 20549

VIA EDGAR

 Attn: Division of Investment Management, Christina Fettig

Re:      Timothy Plan., File Nos. 811-08228 and
033-73248, Sarbanes-Oxley Review of Financial statements and Related items.

 Dear
Ms. Fettig:

 On behalf of the Timothy Plan (the “Trust”), we are filing this letter to respond to comments provided by
yourself to the Trust on January 19, 2022 as a result of your review of the Trust’s September 30, 2021 and December 31, 2020 financial statements, and related matters.

1.
 You noted that many of the Timothy Plan Traditional Funds invest in other affiliated Funds in the Trust. You
further noted that the Funds that are investing in affiliated Trust Funds are purchasing Class A shares, sales loads waived. You asked the Trust to explain why the Funds are purchasing Class A shares instead of less expensive Class I
shares, and to respond to the following items related thereto:

 RESPONSE:

a.
 Please confirm the fund of funds do not pay sales loads when investing in the underlying fund Class A
shares.

 The Funds of Funds were initially offered in 2000. From the date of inception, they have
purchased load-waived Class A shares of the Timothy Plan Underlying Funds.

b.
 Please confirm the fund of funds do not charge 12b-1 fees as it
appears that these funds may charge 12b-1 fees for their Class C shares.

Since their inception in 2000, the Funds of Funds have offered Class A shares and Class C shares. The Funds of Funds
operate under the same 12b-1 Plans as the Underlying Funds. The Funds of Funds are allowed to charge a 12b-1 fee of not greater than 0.25% for Class A shares, and
not more than 1.00% for Class C shares. Since inception, the Funds of Funds have waived all the 12b-1 fee for Class A shares and 0.25% of the 12b-1 fee for
Class C shares, because the Underlying Funds charged a 12b-1 fee of 0.25% for the Class A shares purchased by the Funds of Funds.

c.
 Do the fund of funds use broker/dealers or platforms to invest in the underlying affiliated funds? If not,
please explain why it is appropriate to use money generated by the fund of fund investments to pay trail commissions to support the offering of the underlying funds to retail investors on platforms.

The Funds of Funds do not utilize broker/dealers of platforms to invest in the Underlying Funds. This results in a material
cost savings to the Funds of Funds shareholders.

 The Funds of Funds were created in 2000. At that time, all Funds in the
Trust offered Class A shares and Class C shares. The Trust, then and through today, operated under the mandate that no Fund charge aggregate 12b-1 fees in excess of 0.25% for Class A shares and
1.00% for Class C shares. Since the cheapest shares of Underlying funds in 2000 were Class A shares (load waived), the Funds of Funds were constructed in such a way that aggregate 12b-1 fees for
Class A and Class C shares did not exceed those limits. In order to achieve that, the Trust waived all 12b-1 fees for Class A shares of the Funds of Funds and waived 0.25% of the allowable 12b-1 fee in Class C. Accordingly, by investing in Class A shares of the Underlying funds (load-waived), the maximum aggregate 12b-1 fees for Class A and
Class C shares of the Funds of Funds, as established by the Trust, would not be violated.

 In 2013, thirteen years
after the Funds of Funds commenced operations, the Trust introduced Institutional Shares, and all the Underlying Funds began offering Institutional shares. Institutional shares do not charge any 12b-1 fees.
Institutional shares are restricted as to eligibility. Importantly, the Funds of Funds do not offer Institutional Class shares.

With respect to why it is appropriate to use money generated by the fund of fund investments to pay trail commissions to
support the offering of the underlying funds to retail investors on platforms, that is a simple answer- shareholders of the Funds of Funds pay ongoing 12b-1 fees of 0.25% for their Class A share
purchases, just like every other Class A shareholder of every fund in the Timothy Plan, and Class C shareholders pay total 12b-1 fees of 1.00%, just like every other Class C shareholder of every
other fund in the Timothy Plan.

 Further, for the last two + years, the Funds of Funds have been able to invest in Timothy
Plan ETFs. As of the date of this writing, the Funds of Funds hold about half their assets in Underlying ETFs. The Timothy Plan ETFs do not charge 12b-1 fees. As a result, the effective 12b-1 fee rate paid by Funds of Funds Class A shareholders is around 0.13%. The effective rate paid by Funds of Funds Class C shareholders is around 0.80%.

With the above in mind, it becomes obvious that, under these specific facts, it is entirely appropriate for the Funds of Funds
to continue buying Class A shares (load waived) of the Underlying Funds.

d.
 Please confirm that investing in the Institutional share class of the underlying funds is cheaper than
investing in A shares and provide an analysis explaining the basis of the affiliated fund of funds investing in Class A shares rather than Institutional shares. Please explain how the fund of funds’ board determined that investing in
Class A rather than Institutional shares of the underlying funds was in the best interest of fund of fund shareholders.

For a private investor, who qualifies for investing in Institutional shares of the Underlying Funds, Institutional shares of
those funds are cheaper than Class A shares.

However, a private investor may not buy Institutional Class shares of the Funds of Funds, because those Funds do not offer that share Class. The Funds of Funds offer only Class A shares
and Class C shares. Importantly, every Class A share of every fund in the Timothy Plan imposes an aggregate total 12b-1 fee of 0.25%. Likewise, every Class C share of every fund in the Timothy
Plan imposes an aggregate total 12b-1 fee of 1.00%.

 As stated above,
Institutional Shares, which did not come into existence until August 2013, thirteen years subsequent to the development of the Funds of Funds, are available exclusively to institutions and through investment advisors, and are not offered in a Fund
of Funds format, because we anticipate that investment advisors actively manage their clients’ portfolios, and a fund of funds is therefore counter-intuitive for RIA managed accounts.

It is important to note that at the time the funds of funds were created, great care was taken to provide shareholders with a
product that offered actively managed diversification. As detailed above, the Funds of Funds were constructed to ensure that Class A and Class C shares were effectively identical to Class A and Class C shares of every other
Timothy Plan Fund. 12b-1 fees are not Fund expenses. They are shareholder expenses. If a shareholder went into the market and bought Class A shares of one or all of the underlying Funds, that shareholder
would pay 0.25% per year on every dollar invested in every Fund. If that same shareholder decided to buy Class A shares of a Fund of Funds, the Fund of Funds would buy Class A shares of the Underlying Funds on his/her behalf, and the
shareholder still pays 0.25% annually in 12b-1 fees on every dollar invested, exactly like the direct investor. The same is true for Class C investors.

If the Trust had built the Funds of Funds after 2013, it would have fully implemented Class A shares that charged 0.25%
(instead of 0.00%) and Class C shares that charged 12b-1 fees of 1.00% (instead of 0.75%). Then the Funds of Funds could purchase Institutional Class shares of the Underlying Funds. However, the
Funds of Funds were built almost 14 years earlier, and for the reasons discussed above and below, transitioning to Institutional shares would actually harm shareholders.

The Funds of Funds have the right to discontinue waiving 12b-1 fees and fully
implement direct 12b-1 fees on both Class A and Class C shares. If the Funds of Funds were to stop those waivers and begin charging full 12b-1 fees directly,
the Funds of Funds would then be able to invest in Institutional shares. However, were the Funds of Funds to begin charging 12b-1 fees directly, the Funds of Fund shareholders would pay 0.25% on Class A
shares and 1.00% on Class C shares on every dollar invested on those Funds, even though roughly half of each Fund is invested in Funds that do not charge 12b-1 fees. The Adviser is currently making up the
difference in fees on the platforms. Were the Board to alter the Funds of Funds structure, those shareholders would incur increased effective expenses and the Adviser would receive a windfall.

This puts the Board in an awkward position. It can bow to form over function, fully implement
12b-1 fees at the Funds of Funds level, and purchase Institutional shares of the Underlying Funds, or it can leave things as they are. Altering the Funds of Funds satisfies the form over function element, but
it disadvantages Fund of Funds shareholders and enhances the Adviser’s balance sheet. Even though the Adviser would be thrilled, shareholders would not be so happy, and the Board’s job is to protect shareholders.

2.
 You noted that on page 6 of the September 30, 2021 Annual Report, the Management Discussion of Fund
Performance (“MDFP”) for the Large/Mid Cap Growth Fund

references gross return. In future filings, please ensure that the MDFP discloses net returns.

You further noted that on page 15 on the September 30, 2021 Annual Report, the Management Discussion of Fund Performance
(“MDFP”) for the Defensive Strategies Fund references a return of 14.34%. Staff could not reconcile that number with other disclosures in the report. Please explain the discrepancy.

RESPONSE: Going forward, the Trust will ensure that all MDFP documents will disclose net returns. Further, the noted
discrepancy in returns for the Defensive Strategies Fund was a typographical error. Going forward, the Trust will take greater care in reviewing its disclosures to ensure these types of errors do not recur.

3.
 You noted that on page 5 of the December 31, 2020 Annual Report, the disclosed index for the Timothy
Plan International ETF incudes the word “net”. However, on page 15 of the report, the word “net” is not included in the disclosure. Please explain the discrepancy.

RESPONSE: The correct name of the Index relating to the International ETF is the MSCI EAFE Index. The inclusion of the
word “net” was an inadvertent error. It will be corrected in future filings.

4.
 You noted that the MDFP letters for the Conservative Growth Fund, Conservative Growth Variable Fund,
Strategic Growth Fund and the Strategic Growth Variable Fund did not include discussion reflecting the strategies and techniques that impacted the relevant Fund’s performance, as required under Item 27(b)(7) of Form N-1A. Further, the discussion related to the equity portion of the Growth & Income Fund also did not include discussion reflecting the strategies and techniques that impacted the relevant Fund’s
performance, as required under Item 27(b)(7) of Form N-1A.

RESPONSE: Registrant will ensure that future MD&A Letters are fully compliant with Item 27(b)(7) of Form N-1A.

5.
 You noted that the performance graphs and table for the ETF’s in the December 31, 2020 Annual
Report did not include disclosures required under Item 27(b)(7)(2)(B).

 RESPONSE: Appropriate
disclosure will be added, as necessary, in all future filings.

6.
 You noted that the table showing the growth of $10,000 for the ETF’s in the December 31, 2020
Annual Report references Class A Shares. Since the ETF’s do not offer Class A shares, the disclosure should be corrected in future filings.

RESPONSE: The disclosure will be corrected in future filings.

7.
 You noted that the December 31, 2020 Annual Report for the Large/Mid Cap ETF appears to include a
change to the Fund’s benchmark. Please explain and in future filings comply with the disclosure requirements for benchmark changes as required under Item 27(b)(2), Instruction 7.

RESPONSE: The benchmark relating to the Large/Mid Cap ETF did not change. The Index owner changed the name of the
index.

8.
 You noted that in the September 30, 2021 Annual Report, the Defensive Strategies Fund and the
Growth & Income Fund disclose blended indices as their benchmarks. Please

explain how these blended indices comply with the requirement of a broad-based Index, as required by Item 27(b)(7) of Form N-1A. You further noted that
with respect to the Defensive Strategies Fund, the blended index discussions o pages 15 and 31 are not consistent.

RESPONSE: In future filings, the Trust will ensure that all such disclosures comply with the requirements of Item
27(b)(7) of Form N-1A.

9.
 You noted that on the December 31, 2020 Annual Report, the performance tables for each ETF compare each
Fund’s performance to the Index that each Fund tracks. Form N-1A requires that Funds, including ETF’s, compare their performance against a recognized broad-based index. Please include appropriate
broad based indices in future filings.

 RESPONSE: The Trust will include appropriate broad based
indices in future filings.

10.
 You noted that in the December 31, 2020 Annual Report and September 30, 2021 Annual Report, none
of the Funds disclose a graphical representation of the Funds’ portfolio holdings, as required under Item 27(d)(2) of Form N-1A. You have asked the Trust to ensure that future filings include the required
disclosures.

 RESPONSE: The Trust will ensure that future filings include the required
disclosures.

11.
 You noted that in the December 31, 2020 Annual Report and September 30, 2021 Annual Report, the
following Funds did not include certain required disclosures in their Schedules of Investments as required by Regulation S-X, Article 12-12, Footnote 2, including type
of investment, related industry, and country or geographical location;

 Conservative Growth Variable
Series

 Conservative Growth Fund

Strategic Growth Variable Series

Strategic Growth Fund

Large/Mid Cap Growth Fund

Growth & Income Fund

Fixed Income Fund

High Yield Fund

You have asked the Trust to ensure that future filings include the required disclosures.

RESPONSE:    The Trust will ensure that future filings include the required disclosures.

12.
 You noted that each of the ETF’s pays a unitary fee to the Adviser. You asked that the Trust confirm in
correspondence that the Adviser is current on all obligations owing to other Fund service providers.

RESPONSE: The Trust and Adviser confirm that the Adviser is current on all obligations owing to other Fund service
providers.

13.
 You noted that in the Financial Highlights Tables for the Variable Funds, there should be a disclosure
stating that the returns do not include any fees or expenses imposed by the contract provider. Please include such disclosure in future filings.

RESPONSE: The Trust will ensure that a disclosure stating that the returns do not include

any fees or expenses imposed by the contract provider.

14.
 You noted that Note 1 of the December 31, 2020 Annual Report for the Variable Series includes a
secondary principal investment objective not mentioned in the prospectus. In future filings, please reconcile this discrepancy.

RESPONSE: We will reconcile the discrepancy in future filings.

15.
 You noted that in the September 30, 2021 Annual Report, the Related Party Transactions Note did not
disclose that the Adviser pays the fees of the sub-advisers. You asked that future filings include that disclosure, along with the fee rates paid to each sub-adviser.

 RESPONSE: The Trust will ensure that disclosure noting that the Adviser pays the fees of the sub-advisers, along with the fee rates, will be included in future filings.

16.
 You noted that in the September 30, 2021 Annual Report, page 106 of the report, relating to the
International Fund, t