SecProbe.io

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Mail Stop 4561
      							June 16, 2005

VIA U.S. MAIL AND FAX (954) 964-1548

Mr. Michael P. Pacult
President and Treasurer
101 North Fairfield Drive
Dover, Delaware 19901

      RE:	Bromwell Financial Fund, Limited Partnership
      Form 10-K for the year ended December 31, 2004
      Filed April 8, 2005
      File No.  333-85755
      Form 10-Q for the quarter ended March 31, 2005
      Filed May 20, 2005

Dear Mr. Pacult:

      We have reviewed the above referenced filings and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents.  As such, all persons who are
responsible
for the adequacy and accuracy of the disclosure are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934.

      Where indicated, we think you should revise your documents
in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Comments

Form 10-K for the year ended December 31, 2004

1.  Please file an amendment to your Form 10-K that includes the
entire filing together with the certification of your CEO/CFO in
the
form currently set forth in Item 601(b)(31) and Item 601(b) (32)
of
Regulation S-K.

*    *    *    *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please file your response on EDGAR.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the company 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.

   In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

   You may contact Kelly McCusker, Staff Accountant, at (202) 551-
3433 or the undersigned at (202) 551-3414 if you have questions.

						Sincerely,

      Jorge Bonilla
      Senior Staff Accountant

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Mr. Michael P. Pacult
Bromwell Financial Fund, Limited Partnership
June 16, 2005
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