SecProbe.io

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(STRADLEY RONON ATTORNEYS AT LAW LOGO)       STRADLEY RONON STEVENS & YOUNG, LLP

                                                            1220 19th Street, NW

                                                                       Suite 600

                                                            Washington, DC 20036

                                                        Telephone (202) 822-9611

                                                              Fax (202) 822-0140

                                February 10, 2005

VIA Edgar and Email

Larry L. Greene, Esq.
Division of Investment Management
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Re:      UMB Scout Stock Fund, Inc. (File Nos. 2-79131 and 811-3557), UMB Scout
         WorldWide Fund, Inc. (File Nos. 33-58070 and 811-7472), UMB Scout Bond
         Fund, Inc. (File Nos. 2-79132 and 811-3558), UMB Scout Kansas
         Tax-Exempt Bond Fund, Inc. (File Nos. 333-40845 and 811-8513), UMB
         Scout Money Market Fund, Inc. (File Nos. 2-78688 and 811-3528), UMB
         Scout Tax-Free Money Market Fund, Inc. (File Nos. 2-79130 and 811-3556)
         and UMB Scout Funds (File Nos. 333-96461 and 811-9813) - Response to
         SEC Comments on Preliminary Proxy Solicitation Materials

Dear Mr. Greene:

We are responding to your comments, provided via telephone on February 8, 2005
to the preliminary proxy materials filed on Schedule 14A by UMB Scout Stock
Fund, Inc., UMB Scout WorldWide Fund, Inc., UMB Scout Bond Fund, Inc., UMB Scout
Kansas Tax-Exempt Bond Fund, Inc., UMB Scout Money Market Fund, Inc., UMB Scout
Tax-Free Money Market Fund, Inc. and UMB Scout Funds (each a "Fund" and
collectively, the "Funds") initially filed on January 25, 2005. The preliminary
filing included a separate Q&A (the "Supplemental Q&A") that will accompany the
proxy statement ("Proxy Statement") when mailed to shareholders. Each of your
comments and our response to each comment is set forth below.

In connection with our responses to your comments, we acknowledge, on behalf of
each Fund, that:

o        The Fund is responsible for the adequacy and accuracy of the disclosure
         in the filing;

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

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Larry L. Greene, Esq.
February 10, 2005
Page 2 of 8

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

GENERAL COMMENTS

1.       PURSUANT TO SEC PRESS RELEASE 2004-89 (JUNE 24, 2004), ALL EDGAR
         CORRESPONDENCE SHOULD INCLUDE A "TANDY LETTER" THAT INCLUDES CERTAIN
         ACKNOWLEDGEMENTS.

         RESPONSE: The acknowledgements required in a Tandy letter are included
         as the second paragraph of this response letter.

2.       THE FILING DID NOT INCLUDE A PROXY CARD. EMAIL TO LARRY GREENE AT
         GREENEL@SEC.GOV.

         RESPONSE: The proxy card was emailed as requested on February 8, 2005.
         We have since received your communication indicating that you have no
         comments on the card. The proxy card will be included in the definitive
         filing of the proxy statement.

3.       PER ITEM 4(a)(3) OF SCHEDULE 14A, INCLUDE THE COST OF THE PROXY
         SOLICITOR FIRM IN SOLICITING PROXIES.

         RESPONSE: We have added the following language to the Proxy Statement
         under the section entitled "Solicitation of Proxies:"

         "The cost of the proxy solicitation firm is estimated to be between
         $70,000 and $108,000, which will be paid for by the Advisor."

4.       NARRATIVE LANGUAGE THAT IS PRESENTED IN ALL CAPITAL LETTERS SHOULD NOT
         BE USED FOR EMPHASIS IN THE PROXY STATEMENT.

         RESPONSE: We have changed the font of any affected language so that it
         does not appear in all capitalized letters. However, please note that
         some language appears in all caps due to a limitation in filing via
         Edgar. This language is simply bolded language and not in all caps in
         the printed version of the Proxy Statement.

COMMENTS ON SUPPLEMENTAL Q&A

5.       IN THE SUPPLEMENTAL Q&A, UNDER PROPOSAL 2, CONSIDER EXPLAINING WHETHER
         OR NOT SHAREHOLDER RIGHTS WILL CHANGE AS A RESULT OF THE REORGANIZATION
         OF THE FUNDS FROM MARYLAND CORPORATIONS TO A DELAWARE STATUTORY TRUST.

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Larry L. Greene, Esq.
February 10, 2005
Page 3 of 8

         RESPONSE: The differences resulting from the change from a Maryland
         corporation to a Delaware trust, including any impact on shareholder
         rights, are described in the body of the Proxy Statement and/or in
         Exhibit 2 of the Proxy Statement, which compares and contrasts Maryland
         corporations and Delaware statutory trusts. We believe that the changes
         in shareholder rights are adequately disclosed in those areas and that
         it not be necessary to add information about this issue to the
         Supplemental Q&A.

6.       IN THE SUPPLEMENTAL Q&A, UNDER PROPOSAL 3, THE FIRST ANSWER DOES NOT
         APPEAR TO ANSWER "WHY" THE FUNDS ARE REVISING THE INVESTMENT ADVISORY
         AGREEMENT.

         RESPONSE: We have revised the question that precedes the relevant
         answer to read as follows instead:

         "What changes are being made to the Funds' investment advisory
         agreements?"

7.       IN THE SUPPLEMENTAL Q&A, UNDER PROPOSAL 5, THE ANSWER TO THE FIRST
         QUESTION SHOULD INDICATE THAT EACH FUND'S INVESTMENT OBJECTIVE IS ALSO
         REFERRED TO IN THE PROXY STATEMENT.

         RESPONSE: We believe that it is unnecessary to add this information to
         the Q&A. The language immediately preceding the first question includes
         a sentence that indicates that the Proxy Statement should be consulted
         for additional information on this Proposal. We believe that adding the
         requested language would be redundant.

8.       IN THE SUPPLEMENTAL Q&A, UNDER THE LAST QUESTION OF PROPOSAL 5, PLEASE
         INDICATE THAT SHAREHOLDERS WILL BE NOTIFIED OF ANY CHANGE IN INVESTMENT
         OBJECTIVE AND THAT AS A RESULT, SHAREHOLDERS SHOULD RECONSIDER WHETHER
         THE FUND CONTINUES TO BE AN APPROPRIATE INVESTMENT.

         RESPONSE: We have added the following sentences to the end of the
         answer to this question:

         "Shareholders will be notified if the Board approves a change in a
         Fund's investment objective. In such a case, shareholders will have to
         reconsider whether the Fund continues to be an appropriate investment
         vehicle for the shareholder."

9.       IN THE SUPPLEMENTAL Q&A, UNDER THE FOURTH QUESTION OF PROPOSAL 6,
         PLEASE INDICATE THAT A FUND'S RISK PROFILE MAY CHANGE IF THE BOARD
         CHANGES NON-FUNDAMENTAL POLICIES IN RESPONSE TO MARKET CONDITIONS.

         RESPONSE: We have added the following new sentence to the end of the
         answer to this question:

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Larry L. Greene, Esq.
February 10, 2005
Page 4 of 8

         "However, any such changes made by the Board may affect the risk
         profile of the Fund."

         COMMENTS ON PROXY STATEMENT

10.      UNDER PROPOSAL 1, INDICATE THAT THE NOMINEES HAVE CONSENTED TO BEING
         NAMED IN THE PROXY STATEMENT AND WILL SERVE IF ELECTED.

         RESPONSE:  We have added the following sentence to Proposal 1:

         "Each of the Nominees has consented to being named in this Proxy
         Statement and will serve if elected by shareholders."

11.      CONFIRM SUPPLEMENTALLY THAT EACH FUND DOES NOT HAVE AN ATTENDANCE
         POLICY FOR BOARD MEETINGS AS DESCRIBED IN ITEM 7(h)(3).

         RESPONSE: We confirm that each Fund does not have an attendance policy
         for board meetings.

12.      UNDER PROPOSAL 1, IN THE DIRECTOR COMPENSATION TABLE, PLEASE SEPARATE
         OUT THE INTERESTED AND INDEPENDENT DIRECTORS.

         RESPONSE: We have added the word "Interested Director" beneath Mr.
         McShane's name in the compensation table as he is the only interested
         Director on the Board.

13.      UNDER PROPOSAL 1, IN THE SECTION ENTITLED "SHAREHOLDER APPROVAL,"
         INDICATE WHAT THE TERM "PLURALITY" MEANS.

         RESPONSE: We have added the following sentence to the end of the
         "Shareholder Approval" section:

         "This means that those Nominees receiving the greatest number of votes
         are elected."

14.      IN PROPOSAL 2, INDICATE WHETHER OR NOT THE ACQUIRING FUND IS REGISTERED
         UNDER THE 1940 ACT.

         RESPONSE: We have revised the first sentence under the section entitled
         "Introduction" to read as follows (new language appears with
         underlines):

         "The purpose of this Proposal is to approve an Agreement and Plan of
         Reorganization that provides for the reorganization of the Stock Fund,
         Stock Select Fund, WorldWide Fund, Bond Fund, Kansas Tax-Exempt Bond
         Fund,

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Larry L. Greene, Esq.
February 10, 2005
Page 5 of 8

         Money Market Fund - Federal Portfolio, Money Market Fund - Prime
         Portfolio and Tax-Free Money Market Fund into new series of UMB Scout
         Funds, a Delaware statutory trust (the "Trust") that is registered
         under the 1940 Act."

15.      IN PROPOSAL 2, UNDER THE SECTION ENTITLED "CERTAIN FEDERAL INCOME AND
         STATE TAX CONSEQUENCES OF THE PLAN," INDICATE THE APPLICABLE PROVISIONS
         OF THE INTERNAL REVENUE CODE THAT APPLY TO THE REORGANIZATION AND NOTE,
         IF APPLICABLE, WHETHER ANY LOSS CARRYOVERS WILL BE LOST AS A RESULT OF
         THE REORGANIZATION.

         RESPONSE: There will be no impact to capital loss carryovers
         attributable to the shell reorganization and therefore, we have not
         added any disclosure regarding that issue. We have revised the first
         sentence in this section to read as follows (new language appears with
         underlines) to indicate the applicable section of the Internal Revenue
         Code:

         "It is anticipated that the transactions contemplated by the Plan will
         be tax-free for federal income tax purposes under Section 368 of the
         Internal Revenue Code of 1986, as amended, so shareholders will not
         experience a taxable gain or loss when the Reorganization is
         completed."

16.      IN PROPOSAL 2, UNDER THE SECTION ENTITLED "SHAREHOLDER APPROVAL,"
         INDICATE THE CONSEQUENCES OF SHAREHOLDERS NOT APPROVING THE
         REORGANIZATION.

         RESPONSE: We have added the following new sentence at the end of the
         section:

         "If shareholders of a Fund do not approve the Reorganization, the Fund
         will initially continue to operate under Maryland law. However, the
         Board may explore other alternatives such as liquidating the Fund or
         merging it into another Fund."

17.      IN PROPOSAL 3, UNDER THE SECTION ENTITLED "BOARD APPROVAL AND
         CONSIDERATIONS," PLEASE ELABORATE FURTHER THE CONCLUSIONS REACHED BY
         THE BOARD IN APPROVING EACH NEW INVESTMENT ADVISORY AGREEMENT.

         RESPONSE: We have decided to delete the second sentence of the last
         bullet point and also add the following new paragraph after the list of
         factors in this section:

         "After requesting and reviewing such materials as it deemed necessary,
         and based on the factors described above, the Board concluded that the
         advisory fees and other expenses of each Fund are fair, both absolutely
         and in comparison with those of other funds in each Fund's peer group
         and the industry at large (as summarized in the report prepared by the
         independent consulting firm), the scope and quality of the services to
         be provided by the Advisor to each Fund were consistent with each
         Fund's operational requirements, and that shareholders have
         historically received, and the Board expects that they will continue to
         receive,

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Larry L. Greene, Esq.
February 10, 2005
Page 6 of 8

         reasonable value in return for paying fees to the Advisor. Furthermore,
         in the case of the Small Cap Fund and the WorldWide Fund, where
         historical fees and expenses were significantly below market rates, the
         Board's analysis supported a conclusion to seek an increase in the
         investment advisory fee rates."

18.      IN PROPOSAL 3, CONSIDER REVISING THE HEADING ENTITLED "REDUCTION FROM
         ORIGINAL FEE" IN EACH TABLE THAT DEPICTS MANAGEMENT FEE BREAKPOINTS.

         RESPONSE: We have revised the heading to be "Reduction from Base Fee."

19.      IN PROPOSAL 3, CLARIFY THE LANGUAGE THAT IMMEDIATELY FOLLOWS EACH
         ANNUAL FUND OPERATING EXPENSES TABLE.

         RESPONSE: We have revised the paragraph so that it now reads as follows
         (note - the following is an example of the language under Proposal 3A,
         however, similar changes will be made in Proposals 3B - 3I) (new
         language appears with underlines):

         "For the fiscal year ended June 30, 2004, the Stock Fund paid: (a)
         $1,094,662 in management fees to the Advisor under the unified fee
         structure, of which $840,314 was determined by the Advisor to be
         equivalent to the advisory fee only had the unified fee structure been
         unbundled; and (b) total expenses of $1,116,392, which includes
         expenses not covered by the unified fee structure (e.g., the expenses
         that relate to the "Other Expenses" category above under the "Current"
         column such as registration and insurance fees). On a pro forma basis
         under the proposed advisory agreement and unbundled fee structure, the
         Stock Fund would have paid: (a) $772,686 in advisory fees to the
         Advisor, which represents a decrease of 8.0% in the advisory fee
         component only; and (b) total expenses of $1,159,029, which represents
         an increase of 3.8% in the total expense ratio.

20.      IN PROPOSAL 4, PLEASE INDICATE THAT ANY OF THE SUB-PROPOSALS THAT ARE
         APPROVED BY SHAREHOLDERS WILL BE EFFECTIVE IMMEDIATELY SUBJECT TO
         APPLICABLE DISCLOSURE CHANGES.

         RESPONSE: We have revised the last sentence of the section entitled
         "Introduction" to read as follows (new language appears with
         underlines):

         "Any Proposals that are approved by shareholders will be effective
         immediately, subject to appropriate amendments to the Fund's
         registration statement filed with the SEC."

21.      IN PROPOSALS 4G, 5 AND 6, YOU SUGGEST THAT WE CONSIDER UNBUNDLING THESE
         PROPOSALS INTO SEPARATE PROPOSALS FOR EACH AFFECTED FUND.

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Larry L. Greene, Esq.
February 10, 2005
Page 7 of 8

         RESPONSE: In these proposals, we are merely asking shareholders to
         approve one general change - a reclassification from fundamental to
         non-fundamental objectives, policies or restrictions, as the case may
         be. We believe that separating these into multiple proposals may not be
         practical and would confuse shareholders rather than providing an easy
         to understand proposal upon which shareholders can vote. As a result,
         we respectfully decline to unbundle each of these proposals.

22.      IN PROPOSAL 5, PLEASE INDICATE THAT SHAREHOLDERS SHOULD RECONSIDER
         WHETHER THE FUND CONTINUES TO BE AN APPROPRIATE INVESTMENT IF THE BOARD
         APPROVES A CHANGE IN A FUND'S INVESTMENT OBJECTIVE.