SecProbe.io

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                                  DECHERT LLP
                                1775 I STREET, NW
                              WASHINGTON, DC 20006

VIA EDGAR CORRESPONDENCE

January 21, 2005

Christian Sandoe
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

         Re:       Munder Series Trust, on behalf of the Munder Small Company
                   Growth Fund, Proxy Statement/Prospectus on Form N-14
                   SEC File No. 333-102943

Dear Mr. Sandoe:

         We are writing on behalf of the Munder Series Trust ("Registrant") in
response to additional comments you provided telephonically to Erin Wagner of
this office on Wednesday, January 19, 2004, with respect to a proxy
statement/prospectus filed on Form N-14 for the Registrant ("Proxy Statement").
The Proxy Statement relates to the proposed reorganization of the Munder Small
Company Growth Fund ("Small Company Fund") with and into the Munder Micro-Cap
Equity Fund ("Micro-Cap Fund"), each a series of the Registrant.

         Your comments related to the proposed disclosure concerning the Munder
Funds' policies and procedures concerning frequent purchases and redemptions of
Fund shares. More specifically, you requested that we (1) provide a statement
concerning the risks of frequent purchases and redemptions of Fund shares
specific to the Micro-Cap Fund, (2) state to what extent any of the proposed
measures that the Funds may apply in response to any excessive short-term
trading are discretionary or subjective on the part of the Funds, and (3) state
whether the Funds' policies and procedures are applied uniformly, especially
with respect to trading in Fund shares through financial intermediaries and
omnibus accounts.

Below is revised disclosure to replace in its entirety the disclosure under the
heading in the N-14, "Frequent Purchases and Redemptions of Fund Shares," as
marked to show changes that have been made to incorporate each of your comments.

         The Munder Funds are not intended to serve as vehicles for short-term
         trading. By realizing profits through short-term trading, investors
         that engage in rapid purchases and sales or exchanges of a Fund's
         shares may dilute the value of shares held by long-term investors.
         Volatility resulting from excessive purchases and sales or exchanges of
         a Fund's shares, especially involving large dollar amounts, may disrupt
         efficient portfolio management. In particular, a Fund may have
         difficulty implementing its long-term investment strategies if it is
         forced to maintain a higher level of its assets in cash to

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         accommodate significant short-term trading activity resulting from
         market timing. Excessive purchases and sales or exchanges of a Fund's
         shares may force the Fund to sell portfolio securities at inopportune
         times to raise cash to accommodate short-term trading activity, which
         could cause the Fund to incur increased brokerage costs and to realize
         taxable capital gains without attaining any investment advantage.
         Similarly, the Fund may bear increased administrative costs due to
         asset level volatility and investment volatility that is associated
         with patterns of excessive short-term trading activity. Any
         increased costs are borne by all Fund shareholders, including long-term
         investors who do not cause such costs to be incurred. All of these
         factors may adversely affect Fund performance. Given the Micro-Cap
         Fund's investments in smaller capitalization, less liquid securities,
         the Fund may be more susceptible to market timing, and the risks
         associated with such activity, than funds investing in larger
         capitalization companies.

         The Board of Trustees of the Munder Funds has adopted policies and
         procedures to monitor for, and to discourage and take reasonable steps
         to prevent or minimize, investors from engaging in frequent purchases
         and redemptions of shares of the Munder Funds, to the extent deemed
         reasonable and practicable. The Funds' policies and procedures for
         identifying excessive short-term trading and market timing activities
         take into account a number of factors, including but not limited to,
         the dollar amount and frequency of Fund trades. Pursuant to these
         policies and procedures, each Fund reserves the right to refuse any
         purchase or exchange request that they believe could adversely affect
         the Fund or its operations, including purchase or exchange requests
         from any individual, group or account who, in the Fund's view, is
         likely to engage in excessive trading, or any order that may be viewed
         as market-timing activity. If a Fund refuses a purchase or exchange
         request from a shareholder and that shareholder deems it necessary to
         redeem his or her account in the Fund, any CDSC that is applicable to
         such redemption transaction, as described in the Fund's prospectus,
         will be assessed against those redemption proceeds.

         The Funds will suspend or terminate any or all exchange privileges or
         terminate or suspend telephone and/or internet redemption privileges on
         accounts identified as engaging in excessive short-term trading or
         market timing activity in order to limit these types of trading
         practices. In addition, if you exchange or redeem shares of certain
         Funds within a 60 day period, you will be subject to a short-term
         redemption fee. Limited exceptions apply. Please see the section
         "POLICIES FOR REDEEMING SHARES ---- Short-Term Trading Fee" for more
         information regarding this fee. The Funds (other than a money market
         fund) also reserve the right in the future to limit the number of
         "round trip" exchanges an investor may make into and out of any Fund in
         order to discourage excessive short-term trading activities.

         Although the Funds use a variety of methods to detect and deter
         excessive trading or market timing, the Funds cannot always know or
         reasonably detect such trading, particularly if it is facilitated by
         authorized financial intermediaries or done through

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         omnibus account arrangements. The Funds' ability to monitor and
         discourage market timing and excessive trading generally requires the
         cooperation of financial intermediaries, to effectively implement
         policies and procedures with respect to accounts for which the Funds do
         not have sufficient identifying information. This cooperation cannot
         necessarily be assured. To the extent the Funds are able to identify
         market timing or excessive trading in these accounts, the Funds will
         use their reasonable and best efforts to uniformly apply their policies
         and procedures. (However, there is no guarantee that this goal will be
         achieved.) Finally, it is important to recognize that "market timing"
         and "excessive trading" are not clearly defined terms under applicable
         law. Consequently, trading activities that may not be considered by the
         management of the Munder Funds to be excessive or market timing could
         be interpreted differently by others and vice versa.

                                    * * * * *

     You requested that the Registrant make certain representations concerning
     the Proxy Statement and the response being made to the comments received.
     These representations are included as an exhibit to this letter.

We hope that the foregoing is responsive to the matters discussed with Erin
Wagner on January 19, 2005. Please do not hesitate to contact the undersigned at
(202) 261-3302 or Erin Wagner at (202) 261-3317 if you have any questions
concerning the foregoing.

                                            Sincerely,

                                            /s/ Jane A. Kanter

                                            Jane A. Kanter

cc:      Stephen J. Shenkenberg, Esq.

         Thomas Lemke, Esq.

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                            [MUNDER FUNDS LETTERHEAD]

VIA EDGAR CORRESPONDENCE

January 21, 2005

Christian Sandoe
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

Re:        Munder Series Trust, on behalf of the Munder Small Company Growth
           Fund, Proxy Statement/Prospectus on Form N-14 SEC File No. 333-102943

Dear Mr. Sandoe:

In connection with a response being made on behalf of the Munder Series Trust
("Registrant") to comments you provided with respect to a proxy
statement/prospectus filed on Form N-14 for the Registrant on December 12, 2004
("Proxy Statement"), the Registrant hereby acknowledges that:

     o    the Registrant is responsible for the adequacy and the accuracy of the
          disclosure in the Proxy Statement;

     o    comments of the staff of the Securities and Exchange Commission ("SEC
          Staff") or changes to disclosure in response to SEC Staff comments in
          Proxy Statement reviewed by the staff do not foreclose the Securities
          and Exchange Commission from taking any action with respect to the
          Proxy Statement; and

     o    the Registrant may not assert SEC Staff comments as a defense in any
          proceeding initiated by the Securities and Exchange Commission or any
          person under the federal securities laws.

We hope that the foregoing is responsive to your request made on January 19,
2005. Please do not hesitate to contact the undersigned at (248) 647-9201 if you
have any questions concerning the foregoing.

                                            Sincerely,

                                            /s/ Stephen J. Shenkenberg

                                            Stephen J. Shenkenberg

cc:      Jane A. Kanter, Esq.

         Thomas Lemke, Esq.

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