[LETTERHEAD OF AIG SUNAMERICA MUTUAL FUNDS]
October 30, 2008
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | SunAmerica Equity Funds |
Securities Act File No. 333-153767
Pre-Effective Amendment No. 1
Dear Commissioners:
Pursuant to Rule 461 under the Securities Act of 1933, SunAmerica Equity Funds (the “Registrant”) requests acceleration of the effective date of Pre-Effective Amendment No. 1 to its Registration Statement on Form N-14 (Securities Act File No. 333-153767) (the “Amendment”) so that the Amendment is declared effective on Friday, October 31, 2008, or as soon as practicable thereafter.
If this request is granted, we respectfully request that we be notified by telephone at the time of effectiveness. Please call Elliot Gluck of Willkie Farr & Gallagher LLP at 212-728-8138.
The Registrant hereby acknowledges that, if the Securities and Exchange Commission (or its staff, acting pursuant to delegated authority), declares the filing effective, such action:
(i) does not foreclose the Commission from taking any action with respect to the filing;
(ii) does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
(iii) may not be asserted by the Registrant as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
October 30, 2008
Page 2
| Very truly yours, | ||
| SunAmerica Equity Funds | ||
| By: | /s/ Kathleen Fuentes | |
| Kathleen Fuentes | ||
| Assistant Secretary | ||
| AIG SunAmerica Capital Services, Inc. | ||
| By: | /s/ James Nichols | |
| James Nichols | ||
| President and Chief Executive Officer | ||
