[LOGO OF CITIGROUP] Global Transaction Services
corporate and Two Portland Square
investment banking Portland, ME 04101
Tel. 207 879 1900
Fax 207 822 6677
April 25, 2006
VIA EDGAR AND U.S. MAIL
Mr. Keith O'Connell
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: ICM Series Trust (File 33-4081; 811-8507
Post-Effective Amendment No. 11 to Registration Statement on Form N-1A
Filed on March 2, 2006 (the "Registration Statement")
Dear Mr. O'Connell:
This letter is to confirm that the above-referenced Registration Statement was
filed pursuant to Rule 485(a) under the Securities Act of 1933, as amended,
with an intended effective date of May 1, 2006.
Although the facing sheet to the Registration Statement correctly indicated
that the filing was made pursuant to Rule 485(a), it incorrectly listed
March 2, 2006 as the effective date. As we have discussed, the intended
effective date is May 1, 2006.
* * * * *
If you have any questions regarding the matters discussed above, please feel
free to call me at (207) 822-6116.
Sincerely,
/s/ Margaret Gallardo-Cortez
---------------------------------
Margaret Gallardo-Cortez
Senior Vice President and Counsel
