SecProbe.io

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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>test2.txt
<DESCRIPTION>12B-25 LETTER NOVEMBER 2004
<TEXT>

November 12, 2004

Michael A. Poutre II
President
Blue and White Funds Trust
8383 Wilshire Boulevard, Suite 100
Beverly Hills, California 90211

Re:	Blue and White Funds Trust (the "Registrant")
	File Number:  811-21143

Dear Mr. Poutre:

We have reviewed the Notification of Late Filing on Form 12b-25
(the
"Form") filed October 29, 2004 on behalf of the Registrant related
to
the Form N-CSR for the fiscal period ended August 31, 2004.

Based on our review, we have the following comments:

* According to Part III of the Form, the reason for the
Registrant`s
delay in filing is due to the auditors needing additional
information
in order to complete the audit and issue their report.  As
required
by Rule 12b-25(c) under the Securities Exchange Act of 1934, the
Registrant should have attached as an exhibit a statement signed
by
the auditors stating the specific reasons why they are unable to
furnish the required opinion, report or certification on or before
the date such report must be filed.  The Registrant did not attach
this exhibit to the filing.  Please file the required exhibits.

Based upon the reason stated above, we do not consider the
Registrant`s Form N-CSR to have been filed timely.  Additionally,
it
appears that the Registrant did not mail the annual report to
stockholders within the time required by Rule 30e-1 under the
Investment Company Act of 1940.  Rule 30e-1 requires that "each
report shall be transmitted within 60 days after the close of the
period for which such report is being made".  Please state when
the
Registrant mailed its annual report to stockholders.

The Registrant received a letter dated May 4, 2004 from the staff
addressing the late filing of its February 28, 2003 and August 31,
2003 Forms N-CSR to which Paul, Hastings, Janofsky & Walker`s
letter
dated June 28, 2004 asserted that "both these circumstances were
unique" and "the board affirmed with management its expectation
that
all future Forms N-CSR will be filed in a timely manner".  Based
on
the filing noted above, it does not appear that these
circumstances
were unique.

We expect you to discuss these matters, including our letter, with
the Registrant`s Board of Directors.

Please respond to each of the points raised in this letter and
file
your response as EDGAR correspondence within thirty days of the
date
of this letter.  Before you file in response to this letter or
file
any new information with the Commission, please notify me at (202)
942-0615 so that we may better coordinate our review of your
filing/information.  Please direct any questions you have
regarding
this letter to me at the number indicated above or at
delanoc@sec.gov.

Sincerely,

Christina L. Delano
Accountant

cc:	Michael Glazer
	Paul, Hastings, Janofsky & Walker LLP

      Frank Donaty
	Assistant Director
	Division of Investment Management
	U.S. Securities and Exchange Commission

	Louis P. Becka
	Assistant Director
	Office of Compliance Inspections and Examinations
	U.S. Securities and Exchange Commission

	Brian D. Bullard
	Chief Accountant
	Division of Investment Management
	U.S. Securities and Exchange Commission

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