Dunham Funds AW Withdrawal of amendment

The Dunham Funds

                                            February 11, 2011

Public Filing Desk

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re: Dunham Funds  (CIK No. 0001420040, 1933 Act File No. 333-147999 and 1940 Act File No. 811-22153) Request for Withdrawal of Amendment to Registration Statement on Form N-1A

Dear Sir or Madam:

     The Dunham Funds, a registered investment company (the “Trust”), has determined that the amendment filed pursuant to Rule 485(b) on the Trust’s behalf on December 29, 2010 (accession number0000910472-10-001355 )(the "Amendment") was made in error.  Therefore, it is in the best interests of the Trust and the public that the filing be withdrawn.  Pursuant to Rule 477(a) under the Securities Act of 1933, the Trust hereby requests that the Amendment be withdrawn.

     Please direct any questions concerning this letter to JoAnn Strasser, of Thompson Hine LLP, counsel to the Trust at (513) 352-6700.

Very truly yours,

/s/ James R. Colantino

James R. Colantino

Assistant Treasurer

cc: Linda Stirling, Securities and Exchange Commission