THE CUTLER TRUST
July 27, 2012
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: The Cutler Trust (the "Registrant")
File Nos. 811-07242; 33-52850
Registration Statement on form N-14
Ladies and Gentlemen:
Enclosed for filing on behalf of the Registrant named above is its Registration Statement on Form N-14.
The filing relates to the proposed reorganization of The Elite Growth & Income Fund (the "Growth & Income Fund"), a series of The Elite Group, into the Cutler Equity Fund (the "Equity Fund"), a series of the Registrant. The proposed transaction is structured to qualify as a tax-free reorganization in which the Registrant would issue shares of the Equity Fund to the shareholders of the Growth & Income Fund in exchange for the Growth & Income Fund's assets at relative net asset value.
By virtue of the transaction, shareholders of the Growth & Income Fund would become shareholders of the Equity Fund and would hold shares of the Equity Fund of a value equal to the net asset value of the shares of the Growth & Income Fund held by them immediately prior to the transaction.
Please contact Tina Bloom at 513/587-3418 if you have any questions concerning this filing.
Very truly yours,
/s/ Tina H. Bloom
Tina H. Bloom
Secretary