SecProbe.io

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                                 MCMORGAN FUNDS

                                                           December 15, 2004

Mr. Jeff Long
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC  20549

Re:  Form N-CSR dated June 30, 2004 for McMorgan Funds;
     Form N-1A filed October 15, 2004 for McMorgan Funds;
     File Number: 811-8370
     ----------------------------------------------------

Dear Mr. Long:

         On behalf of the McMorgan Funds (the "Trust"), this letter responds to
the comments you provided by telephone to Michael Hession of New York Life
Investment Management LLC ("NYLIM") on November 10, 2004, with respect to the
above-referenced filings. NYLIM provides administrative services to the Trust.
Your comments are set forth below in italics, and each is followed by the
Trust's response.

COMMENTS REGARDING THE ANNUAL REPORT DATED JUNE 30, 2004
--------------------------------------------------------

         1.  The performance graphs are missing the disclosure required under
             Item 21(b)(7) of Form N-1A.

                  Currently, the performance table and graph in the Trust's
                  shareholder report are accompanied by a disclosure stating
                  "Before taxes on distributions or redemption of Fund shares."
                  We will amend this disclosure in future reports to state:

                  "The graph and table do not reflect the deduction of taxes
                  that you would pay on fund distributions or the redemption of
                  fund shares."

         2.  Why do the performance graphs show the growth of $1,000 rather than
             $10,000 as required under Item 21(b)(7)(ii)(A)?

                  We agree that Item 21(b)(7)(ii)(A) requires performance graphs
                  showing the growth of $10,000. Going forward, we will ensure
                  that the Trust's annual and semi-annual reports contain
                  performance graphs that show the growth of $10,000 rather than
                  $1,000.
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         3.  On page 30, the Schedule of Investments for the High Yield Fund
             shows a holding of O'Sullivan Industries, Inc. under Household
             Durables. Discuss the valuation of this holding, as the principal
             amount listed is $200,000, while the value is listed as $91,000.

                  O'Sullivan Industries was priced at $45.50 based on a price
                  provided by FT/IDC, an independent pricing service, on June
                  30, 2004 ($200,000 shares at $45.50 = $91,000 market value).
                  J.J. Kenny also priced this security at $45.00 on June 30,
                  2004. This security was purchased in November 2003 at $79.00
                  for a total value of $158,000. The security was sold in August
                  2004 for $51.00.

         4.  On the Statement of Assets and Liabilities, the Principal
             Preservation Fund shows TA fees expenses of $50,339 and liabilities
             $43,208 and on the Equity Investment Fund, TA fees expenses of
             $72,686 and liabilities $60,846. Why is the liability so high?
             How often are the expenses paid?

             Transfer agent out of pocket expenses are billed on a monthly
             basis, two months in arrears. The current liability on these Funds
             includes accrued but unpaid expenses of transfer agent
             out-of-pocket expenses from January 2003.

             In March 2003, questions arose regarding certain expenses on the
             January out-of-pocket invoice. By June 2004, the billing
             discrepancies were resolved and final and amended invoices were
             re-issued for January 2003 to April 2004. Since then, appropriate
             documentation has been provided to McMorgan personnel and the
             accrued amounts have been approved for payment.

         5.  As a best practice, list the financial highlights for each class in
             a separate table.

                  We agree with this suggestion, and in future filings, we will
                  list the financial highlights for each class in a separate
                  table.

         6.  The first sentence of Note 7 to the Financial Statements regarding
             restricted securities reads: "The fund may invest in securities
             that are subject to legal or contractual restrictions on resale."
             Provide clarification of the fund or funds to which this sentence
             refers.

                  Going forward, we will use a defined term when referring to a
                  series of the McMorgan Funds and will revise this sentence to
                  read, "Each Fund (other than the McMorgan Principal
                  Preservation Fund) may invest in securities that are subject
                  to legal or contractual restrictions on resale."

         7.  The signature page of Form N-CSR is missing a date.

                  We will add the missing date and refile Form N-CSR on the date
                  of this letter or shortly thereafter. Going forward, we will
                  ensure that all required dates are included on the signature
                  page of Form N-CSR.

COMMENTS REGARDING THE FORM N-1A FILED OCTOBER 15, 2004
-------------------------------------------------------

         8.  The statement regarding availability of additional information
             regarding the Board of Trustees in the Statement of Additional
             Information (Item 21(b)(6)) is missing.
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                  In the future, we will include in the financial statements a
                  statement indicating that the Statement of Additional
                  Information includes additional information regarding the
                  members of the Board of Trustees and is available upon request
                  without charge. We will also include a toll-free or collect
                  telephone number that shareholders can call to request the
                  Statement of Additional Information.

         9.  The portfolio turnover rate for the Balanced Fund increased from 56
             percent in 2003 to over 100 percent in 2004, but this is not
             addressed in the discussion of investment strategies in the
             Statement of Additional Information.

                  The turnover increase resulted not from a change of style or
                  process but what can be described as an increased level of
                  active management that was precipitated by opportunities
                  presented by the market. In the future, we will include
                  disclosure of the turnover rate in the Prospectus and/or the
                  Statement of Additional Information.

         The Trust acknowledges that:

             o    The Trust is responsible for the adequacy and accuracy of the
                  disclosure in the filings;

             o    Staff comments or changes to disclosure in response to staff
                  comments in the filings reviewed by the staff do not foreclose
                  the Securities and Exchange Commission from taking any action
                  with respect to the filing; and

             o    The Trust may not assert staff comments as a defense in any
                  proceeding initiated by the Securities and Exchange Commission
                  or any person under the federal securities laws of the United
                  States.

                                      * * *

         We hope that this letter is responsive to your comments. If you have
any questions regarding the information set out above or any additional
comments, please call the undersigned at (415) 616-9372 or Bibb L. Strench at
(202) 383-0509.

                                 Sincerely,

                                 /s/ Teresa Matzelle
                                 -------------------
                                 Teresa Matzelle
                                 Vice President,
                                 McMorgan & Company LLC

cc: Michael Hession, Esq.
     New York Life Investment Management LLC

     Bibb L. Strench, Esq.
     Sutherland Asbill & Brennan LLP

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