Law Offices
Stradley Ronon Stevens & Young, LLP
2600 One Commerce Square
Philadelphia, Pennsylvania 19103-7098
(215) 564-8000
June 16, 2010
VIA EDGAR TRANSMISSION
Christina DiAngelo
U.S. Securities and Exchange Commission
Division of Investment Management
Office of Chief Accountant
100 F Street, N.E.
Washington, DC 20549
| | Re: | Voyageur Mutual Funds III (the “Registrant) |
| | Registration Statement on Form N-14 |
| | 1933 Act Registration No. 333-167200 |
Dear Ms. DiAngelo:
On behalf of the above-referenced Registrant, attached is a memorandum providing the accounting survivor analysis requested by the Staff in connection with the Registration Statement on Form N-14 filed by the Registrant on May 28, 2010 pursuant to Rule 488 under the Securities Act of 1933, as amended.
If you have any questions or comments regarding this filing, please call me at (215) 564-8553 or Ken Greenberg at (215) 564-8149.
Sincerely,
/s/ Nicolas Lombo
Nicolas Lombo
