Dunham Funds
February 24, 2011
VIA ELECTRONIC TRANSMISSION
Linda Stirling
Senior Counsel
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
RE:
Dunham Funds
CIK No. 0001420040
Securities Act File No. 333-147999
Investment Company Act File No.811-22153
Post-Effective Amendment No. 15
Dear Ms. Stirling:
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Securities Act”), the Dunham Funds (the “Trust”) hereby requests that the effectiveness for Post-Effective Amendment Number 15 to the above-referenced Registration Statement on Form N-1A be accelerated to March 1, 2011, or as soon thereafter as practicable. The Trust hereby confirms that it is aware of its obligations under the Securities Act and the Securities Exchange Act of 1934, as amended.
Dunham Funds | Dunham & Associates Investment Counsel, Inc. |
By: /s/Denise S. Iverson Name: Denise S. Iverson Title: Treasurer | By: /s/Denise S. Iverson Name: Denise S. Iverson Title: Chief Financial Officer |
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