SecProbe.io

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                               PEPPER HAMILTON LLP
                              3000 TWO LOGAN SQUARE
                           EIGHTEENTH AND ARCH STREETS
                           PHILADELPHIA, PA 19103-2799

                                  March 9, 2005

VIA EDGAR

Mr. Jeff Long
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

        Re: WT Mutual Fund (1940 Act File No. 811-08648)
            --------------------------------------------

Dear Mr. Long:

         This letter responds to your oral comments received on Tuesday, January
25, 2005, regarding the financial statements contained in the annual reports of
various series (the "Series") of the WT Mutual Fund (the "Trust"), which were
filed with the Commission on Form N-CSR on September 9, 2004. We appreciate the
opportunity to address your comments regarding the current disclosure contained
in the Financial Statements of certain of the Series.

         We have organized the comments you presented and our response to such
comments in the order in which they were delivered.

         1. You commented that the line graphs required under Item 21(b)(7) of
Form N-1A, "Management's Discussion of Fund Performance," in the Annual Reports
of each of the Series as filed electronically on EDGAR, did not include a
tabular presentation of the data as required under Rule 304(a) of Regulation ST.

         This will confirm that all future line graphs not reproduced
         graphically in the Annual Reports of the Series will include a tabular
         presentation of the data as required under Rule 304(a) of Regulation
         ST.

         2. You questioned the accuracy of the fact that each of the Roxbury
Funds' (i.e., Small Cap Growth, Mid Cap Fund and Large Cap Growth Fund)
Statement of Assets and Liabilities disclosed the exact same amount (i.e.,
($3,028)) under the "Accumulated Net Investment Loss" line item.

         The amount shown within the components of net assets on each Fund's
         statement of assets and liabilities represents a temporary book-tax
         timing difference relating to the Deferred Compensation Plan for
         Independent Trustees (the "Plan") (Exhibit 22(f) to the Trust's
         registration statement). The fees, including any deferred fees under
         the Plan, for the Independent Trustees are allocated on a pro rata
         basis to each of the series of the Trust, such that the identical
         amounts are allocated to each series. As the deferred amounts represent
         book-tax timing differences that will reverse in the future upon
         distribution from the Plan, these amounts have not been reclassified to
         "Paid-in-capital." This treatment is consistent with AICPA Statement of
         Position 93-2, Determination, Disclosure, and Financial Statement
         Presentation of Income, Capital Gain, and Return of Capital
         Distributions by Investment Companies.
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         3. You noted that all foreign exchange contract transactions are to be
reported on a gross basis and asked for confirmation as to whether or not a
master netting arrangement is in place for the Wilmington International
Multi-Manager Portfolio (the "Portfolio").

         At June 30, 2004, the open forward foreign currency exchange contracts
         for the Portfolio were with two counterparties -- Brown Brothers
         Harriman & Co. ("BBH") and Goldman Sachs & Co. ("GS"). The net amounts
         due to BBH and GS were $21,479 and $38,285, respectively, the sum of
         which ($59,764) is presented as a liability on the statement of assets
         and liabilities. As such, the amounts due to BBH and GS have not been
         netted for financial reporting purposes, as the Portfolio was in a "net
         payable" position with both counterparties.

         4. You asked for an explanation of why the CRM Mid Cap Value Fund made
distributions of 2(cent) per share with respect to each of its Institutional
Class and Retail Class Shares, when Institutional Class Shares had a 3(cent) per
share gain and the Retail Class Shares had a 5(cent) per share loss.

         As you are aware, Rule 18f-3 neither mandates nor indicates how
         distributions are to be made among the various classes of a multi-class
         fund. Accordingly, the pro rata distribution among all classes of a
         fund is not inappropriate. Moreover, nothing in the Trust's Declaration
         of Trust or Bylaws would prohibit a pro rata distribution among
         shareholders of each class of a series. However, after review of this
         matter, it appears that industry practice is to compute and declare
         distributions that resemble the variance in class level expenses.
         Accordingly, this matter will be discussed with the Trust's Board to
         determine whether the current practice of making distributions on a pro
         rata basis should be modified to reflect current industry practice.

         5. You asked for an explanation of how the administrative and
accounting fee waivers with respect to each of the Series are in compliance with
Rule 18f-3.

         In accordance with the Trust's Administrative and Accounting Service
         Agreement (the "Agreement"), each series of the Trust is charged an
         annual series level fee plus a class level fee for each class. The
         Agreement also provides that such series/class level fees will be
         waived to the extent the series/class average net assets do not exceed
         specified levels. The terms of the Agreement are disclosed in Note 3 to
         the financial statements of each Series. For accounting, as well as
         financial reporting purposes, the class level fees and corresponding
         waivers are recorded at the class level. Given the fact that separate
         accounting records must be maintained for each class, this treatment is
         consistent with Rule 18f-3 which states that, "Each class may pay a
         different share of other expenses, not including advisory or custodial
         fees or other expenses related to the management of the company's
         assets, if these expenses are actually incurred in a different amount
         by that class, or if the class receives services of a different kind or
         to a different degree than other classes. . . ."

         6. You commented that the disclosure in Note 4 to the Roxbury Small Cap
Growth Fund's (the "Fund") financial statements reporting long-term gain
distributions of $0 is inconsistent with the Statement of Changes in Net Assets,
which shows distributions from net realized gains of $837,985.

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         The Fund commenced operations on January 2, 2003. The net realized
         gains distributed during the year ended June 30, 2004, were from net
         short-term capital gains. For Federal income tax purposes, net
         short-term gains are treated as "ordinary income" and, therefore, were
         appropriately characterized as such in Note 4 to the financial
         statements. On a prospective basis, the Fund will add disclosure
         indicating that distributions from net short-term gains are treated as
         ordinary income for Federal income tax purposes.

                                  * * * * * * *

         We trust that these responses address your comments.

         This letter incorporates by reference the "Tandy Letter" signed by an
officer of the Trust and attached hereto as Exhibit A.

         If you have any further questions, please do not hesitate to contact
Joseph V. Del Raso at (215) 981-4506 or my associate Adam L. Lantz at (215)
981-4602.

                                            Very truly yours,

                                            /s/ Joseph V. Del Raso
                                            -----------------------------
                                            Joseph V. Del Raso, Esquire

cc: Robert J. Christian, President, WT Mutual Fund
    John R. Giles, Chief Financial Officer, WT Mutual Fund
    Adam L. Lantz, Esq.

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                                    EXHIBIT A

                                 WT MUTUAL FUND
                            1100 North Market Street
                              Wilmington, DE 19890

                                  March 9, 2005

Filing Desk
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

                 Re:  WT Mutual Fund (the "Fund")
                      Securities Act File No. 33-84762
                      Investment Company Act File No. 811-08648
                      -----------------------------------------

Dear Sir or Madam:

         In connection with the Fund's response to certain oral comments
received from the Commission staff on January 25, 2005, with respect to the
financial statements of its series filed on Form N-CSR on September 9, 2004
("Financial Statements"), the Fund is providing the following, as instructed:

         The Fund acknowledges that (i) it is responsible for the adequacy and
accuracy of the disclosure in its Financial Statements, (ii) Commission staff
comments or changes to disclosure in response to staff comments in its Financial
Statements reviewed by the staff do not foreclose the Commission from taking any
action with respect to the Financial Statements, and (iii) the Fund may not
assert staff comments with respect to the Financial Statements as a defense in
any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

         Please direct any questions concerning this letter to Joseph V. Del
Raso, Esquire, of Pepper Hamilton LLP, counsel to the Fund at 215.981.4506.

                                       Very truly yours,

                                       /s/ Robert J. Christian
                                       Robert J. Christian
                                       President and CEO, WT Mutual Fund

cc: Mr. Jeff Long, Securities and Exchange Commission
    Joseph V. Del Raso, Esq.
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