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      VIA EDGAR AND EMAIL

      U.S. Securities and Exchange Commission

      Division of Investment Management

      Office of Disclosure and Review

      100 F Street, NE

      Washington, D.C. 20549

      Attention:  Ms. Christina DiAngelo Fettig

      Re: Community
            Development Fund (File No. 811-23080)

      Ms. Fettig:

      This letter responds to comments of the Securities & Exchange Commission (the “SEC”) Staff given by you to SEI Investments Global Funds Services (“SEI”), Administrator to the
        Community Development Fund (the “Fund”), in a telephone conversation on March 30, 2022.  The comments provided relate to:

                a.

                the annual report of the Fund as of December 31, 2021, as filed on Form N-CEN (the “2021 Form N-CEN Annual Report”);

                b.

                the annual report of the Fund as of December 31, 2020, as filed on Form N-CEN (the “2020 Form N-CEN Annual Report”);

                c.

                the annual report of the Fund as of December 31, 2021, as filed on Form N-CSR (the “2021 Form N-CSR Annual Report”);

                d.

                the annual report of the Fund as of December 31, 2020, as filed on Form N-CSR (the “2020 Form N-CSR Annual Report”) (said 2021 Form N-CEN Annual Report, 2020 Form N-CEN
                  Annual Report, 2021 Form N-CSR Annual Report, and 2020 Form N-CSR Annual Report hereinafter referred to collectively as the “Reports”);

                e.

                the Prospectuses, dated May 1, 2021, and May 1, 2022, of the Fund as included in the Fund’s Registration Statement on Form N-1A; and

                f.

                related filings of the Fund.

        Community Development Fund (File No. 811-23080)

        April 29, 2022

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      SEI provides the Fund with administrative and accounting services, as well as with officers and other personnel, and submits these responses on behalf of the Fund.

      We have reproduced the substance of the SEC Staff’s comments below, with each comment followed by the Fund’s corresponding response.

      ANNUAL REPORT FOR REGISTERED INVESTMENT COMPANIES ON FORM N-CEN:

      SEC Comment 1:

      Please explain why the Fund’s 2021 Form N-CEN Annual Report did not include a response to Item C.21 of the Form N-CEN.

      Fund Response to Comment 1:

      The Fund’s 2021 Form N-CEN Annual Report inadvertently did not include a response to Item C.21 of the Form N-CEN Annual Report.  This response by the Fund to
        Item C.21 of the Form N-CEN Annual Report should have disclosed “No,” as the Fund did not engage in swing pricing during the Fund’s fiscal-year-ended December 31, 2021.

      The Fund shall be certain to include the appropriate response to Item C.21 of the Form N-CEN Annual Report in future filings of the Fund’s Form N-CEN Annual
        Report.

      ANNUAL REPORT FOR REGISTERED INVESTMENT COMPANIES ON FORM N-CSR:

      SEC Comment 2:

      Item 27(d)(3), “Financial Statements; Annual and Semi-Annual Reports; Statement Regarding Availability of Quarterly Portfolio Schedule,” of the SEC Instructions
        to Form N-1A (the “Form N-1A Instructions”) requires that the Fund’s 2021 Form N-CSR Annual Report include the following statement (the “Portfolio Holdings Statement”), which Portfolio Holdings Statement should reference the Fund’s Form N-PORT
        filings:

      (i) The Fund files its complete schedule of portfolio holdings with the Commission for the first and third quarters of
        each fiscal year as an exhibit to its reports on Form N-PORT; (ii) the Fund’s Form N-PORT reports are available on the Commission’s Web site at http://www.sec.gov; and (iii) if the Fund makes the information on Form N-PORT available to shareholders
        on its Web site or upon request, a description of how the information may be obtained from the Fund.

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      The Portfolio Holdings Statement included on the Table of Contents Page to the Fund’s 2021 Form N-CSR Annual Report, however, references the Fund’s
        formerly-filed Form N-Q quarterly statements.  In future Form N-CSR Annual Report Filings by the Fund, please update the disclosure in the Fund’s Portfolio Holdings Statement in accordance with Item 27(d)(3) of the Form N-1A Instructions.

      Fund Response to Comment 2:

      We agree with the SEC Staff’s comment.  Going forward, the Fund shall update the disclosure in the Fund’s Portfolio Holdings Statement to be included in future
        filings by the Fund on the Form N-CSR Annual Report so that this disclosure is in accordance with Item 27(d)(3) of the Form N-1A Instructions.

      SEC Comment 3:

      Item 27(d)(5), “Financial Statements; Annual and Semi-Annual Reports; Statement Regarding Availability of Proxy Voting Record,” of the Form N-1A Instructions
        requires that the Fund’s 2021 Form N-CSR Annual Report include information (the “Proxy Voting Record Information”) “regarding how the Fund voted proxies relating to portfolio securities during the most-recent twelve-month period ended June 30th
        is available:  (i) without charge, upon request, by calling a specified toll-free (or collect) telephone number; or on or through the Fund’s Web site at a specified Internet address; or both; and (ii) on the Commission’s Web site at
        http://www.sec.gov.

      The Proxy Voting Record Information included on the Table of Contents Page to the Fund’s 2021 Form N-CSR Annual Report, however, does not include the disclosure
        that references how the Fund voted proxies relating to portfolio securities during the most-recent twelve-month period ended June 30th in accordance with Item 27(d)(5) of the Form N-1-A Instructions. Please update the disclosure in
        future filings.

      Fund Response to Comment 3:

      We agree with the SEC Staff’s comment.  Going forward, the Fund shall update the disclosure in the Fund’s Proxy Voting Record Information to be included in
        future filings by the Fund on the Form N-CSR Annual Report so that this disclosure is in accordance with Item 27(d)(5) of the Form N-1A Instructions.

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      SEC Comment 4:

      The Fund’s investments in futures instruments appear to have significantly affected the Fund’s performance for the year-ended December 31, 2021, however, the
        letter from the Fund’s President to the Fund’s shareholders (the “Fund Shareholder Letter”) at Pages 1-3, which is included in the Management’s Discussion of Financial Performance at Pages 1-5, of the Fund’s 2021 Form N-CSR Annual Report, does not
        include any discussion regarding the affect that the Fund’s investments in futures instruments had on the Fund’s performance for the year-ended December 31, 2021.

      Please explain why the Fund Shareholder Letter does not include any discussion regarding the affect that the Fund’s investments in futures instruments had on
        the Fund’s performance for the year-ended December 31, 2021.

      Fund Response to Comment 4:

      The Fund invests primarily in fixed-income assets, many of which assets have longer maturities.  The Fund uses derivatives exclusively to hedge and reduce
        interest-rate risk resulting from these primary investments.  The Fund’s use of futures during the fiscal-year-ended December 31, 2021, lowered the effective duration of the Fund’s holdings from 3.62 years to 2.49 years and the Fund’s overall
        performance for the period would have been lower but for the Fund’s use of futures.

      Accordingly, in preparing the Management’s Discussion of Financial Performance in the Fund’s 2021 Form N-CSR Annual Report, the Adviser determined that, after
        considering the facts that the Fund’s use of futures is disclosed elsewhere in the Fund’s financial statements and that futures are used for risk-management purposes, and not as a means of taking active investment positions, a discussion of futures
        would not be material to shareholders and need not be highlighted in the Fund Shareholder Letter.  Given the SEC Staff’s comment, the Fund shall be sure carefully to consider whether the Fund’s use of futures should be discussed in next year’s Fund
        Shareholder Letter.

      SEC Comment 5:

      In regard to the Sector Weightings Chart at Page 6 of the Fund’s 2021 Form N-CSR Annual Report, there are no disclosures stating if derivatives are included in
        the chart.  In future filings, please disclose whether derivatives are reflected in the Sector Weightings Chart or add disclosures stating the Fund’s derivatives are not disclosed in the Sector Weightings Chart.

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      Fund Response to Comment 5:

      We agree with the SEC Staff’s comment.  Going forward, the Fund shall update the disclosure in the Fund’s Sector Weightings Chart of the Fund’s Form N-CSR Annual Report to include, in future filings by the Fund on the Form N-CSR Annual Report, language that states the Fund’s derivative holdings are not
          included in the Fund’s Sector Weightings Chart, as long as total investments are being used as the denominator.

      SEC Comment 6:

      To the extent that the Fund has any open payables owed to the Fund’s Trustees, please add the disclosure required by Section 6.04.12, “Balance Sheets;
        Liabilities; Other Liabilities,” and Section 6.03(l), “Special rules of general application to registered investment companies and business development companies; Inapplicable Captions,” of Regulation S-X, to the Fund’s Statement of Assets and
        Liabilities at Page 13 of the Fund’s 2021 Form N-CSR Annual Report.

      Fund Response to Comment 6:

      The Fund did not have any Trustee fees payable.  If the Fund did have any Trustee fees payable, then these payables shall be broken out and disclosed in future
        filings by the Fund on the Form N-CSR Annual Report.

      SEC Comment 7:

      Please confirm that, in accordance with the requirements of Section 6.07.2(b), “Statements of Operations; Expenses,”  any expenses of the Fund that represent
        five-percent (5%) or more of the Fund’s total expenses have been separately disclosed under “Other” under “Expenses” in the “Statement of Operations” of the Fund at Page 14 of the Fund’s 2021 Form N-CSR Annual Report.

      Fund Response to Comment 7:

      The Fund did not have any expenses greater than five percent (5%) of the Fund’s total expenses to be included under “Other” expenses in the Fund’s Statement of Operations at Page 14 of the Fund’s 2021 Form N-CSR Annual Report.

      Going forward, we shall separately disclose any expenses of the Fund that represent five-percent (5%) or more of the Fund’s total expenses under “Other” under
        “Expenses” in the Fund’s Statement of Operations to be included in future filings of the Fund’s Form N-CSR Annual Report.

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      SEC Comment 8:

      The “Statement of Changes In Net Assets” at Page 15 of the Fund’s 2021 Form N-CSR Annual Report indicates
          that the Fund has experienced small amounts of Return of Capital for the Fund’s fiscal-years-ended December 31, 2021 and December 31, 2020.

      Section 19(a) of the 1940 Act generally prohibits a fund from making a distribution to fund shareholders from any source other than the fund’s net income,
        unless that payment to fund shareholders is accompanied by a written statement that adequately discloses the source or sources of the payment.  Rule 19a-1 under the 1940 Act specifies the information that is required to be disclosed in the written
        statement (hereinafter, the “Rule 19a-1 Notice”); and Rule 19a-1(a) also states that every written statement “shall be made on a separate paper.”

      The Fund’s response to Item B.23 in the Fund’s 2020 Form N-CEN Annual Report indicates that the Fund sent out Rule 19a-1 Notices to the Fund’s shareholders
        during the Fund’s fiscal-year-ended December 31, 2020; however, the Fund’s response to Item B.23 in the Fund’s 2021 Form N-CEN Annual Report indicates that the Fund did not send out Rule 19a-1 Notices to the Fund’s shareholders during the Fund’s
        fiscal-year-ended December 31, 2021.

      Please confirm whether the Fund sent out Rule 19a-1 Notices to the Fund’s shareholders during the Fund’s fiscal-year-ended December 31, 2021 and, if the Fund
        did not send out these Rule 19a-1 Notices to the Fund’s shareholders during the Fund’s fiscal-year-ended December 31, 2021, please explain why.

      Fund Response to Comment 8:

      The Fund declares distributions to the Fund’s shareholders on a monthly frequency.  The dividend distributions declared and paid by the Fund during the Fund’s
        fiscal-years-ended December 31, 2021 and December 31, 2020, were made from the Fund’s net investment income.  The Fund, therefore, did not provide Rule 19a-1 notices to shareholders during the Fund’s fiscal-year-ended December 31, 2021 and
        responded to Item B.23 in the 2021 Form N-CEN Annual Report as “No.” The Fund, though, inadvertently responded “Yes” to Item B.23 in the Fund’s 2020 Form N-CEN Annual Report.

      The small amounts of “Return of Capital” disclosed on the Statement of Changes In Net Assets is due to a tax-character reclassification of dividends declared
        and paid by the Fund during the Fund’s fiscal-years-ended December 31, 2021 and December 31, 2020.  This tax-character evaluation is done annually at year-end in conjunction with the preparation of the annual financial statements of the Fund.  The
        “Notice To Shareholders: Federal Income Tax Information” at Page 42 of the Fund’s Form N-CSR Annual Report for the Fund’s fiscal-year-ended December 31, 2021, discloses the appropriate notice to

        Community Development Fund (File No. 811-23080)

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      shareholders that provides federal tax information on the dividends (and capital-gains) distributions by the Fund for the Fund’s fiscal-year-ended December 31,
        2021.

      SEC Comment 9:

      In the Security Valuation disclosure in Note 2, “Significant Accounting Policies,” of the Notes to the Financial Statements, at Pages 18-20 of the Fund’s 2021
        Form N-CSR Annual Report, please disclose how the Fund’s investments in other mutual funds are valued.

      Fund Response to Comment 9:

      We agree with the SEC staff’s comment.  Going forward, in future filings by the Fund on the Form N-CSR Annual Report, we shall include appropriate disclosure,
        in the Note regarding “Significant Accounting Policies” in the Notes to the Financial Statements in the Fund’s Form N-CSR Annual Report, how the Fund’s investment in other mutual funds are valued.

      SEC Comment 10:

      The line item “Interest Payable” under “Liabilities” in the Fund’s “Statement of Assets and Liabilities,” at Page 13 of the Fund’s 2021 Form N-CSR Annual
        Report, has a parenthetical reference to Note 2, “Significant Accounting Policies.”

      Note 2, “Significant Accounting Policies,” of the Notes to the Financial Statements, at Pages 18-20 of the Fund’s 2021 Form N-CSR Annual Report, however, does
        not include any reference to “Interest Payable.”

      Please explain the inconsistency between the Fund’s financial statement line item, “Interest Payable,” on the Fund’s “Statement of Assets and Liabilities” and
        Note 2, “Significant Accounting Policies,”  of the Fund’s Notes to the Financial Statements.

      Fund