July 13, 2006
VIA EDGAR
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Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: DWS Advisor Funds
Securities Act File No. 033-07404, Investment Company Act File No.
811-04760 CIK No: 0000797657
Withdrawal of Post-Effective Amendments Nos. 123, 126, 130, 132, 135
and 140
Ladies and Gentlemen:
Pursuant to Rule 477 under the Securities Act of 1933, as amended, DWS Advisor
Funds, a Massachusetts business trust (the "Trust"), on behalf of its series,
DWS International Equity Fund (the "Fund"), hereby respectfully requests that
the following post-effective amendments be withdrawn, and that an order of the
Commission granting such withdrawal be included in the Trust's file for the
Registration Statement:
o Post-Effective Amendment No. 123
Form Type: 485APOS
File Date: December 23, 2005
Accession No.: 0000088053-05-001459
o Post-Effective Amendment No. 126
Form Type: 485BXT
File Date: February 21, 2006
Accession No.: 0000088053-06-000156
o Post-Effective Amendment No. 130
Form Type: 485BXT
File Date: March 23, 2006
Accession No.: 0000088053-06-000328
o Post-Effective Amendment No. 132
Form Type: 485BXT
File Date: April 21, 2006
Accession No.: 0000088053-06-000415
o Post-Effective Amendment No. 135
Form Type: 485BXT
File Date: May 19, 2006
Accession No.: 0000088053-06-000516
o Post-Effective Amendment No. 140
Form Type: 485BXT
File Date: June 16, 2006
Accession No.: 0000088053-06-000646
The above referenced post-effective amendments to the Registration Statement
were filed to offer a new Institutional Class for the Fund, which was to offer
its shares to the shareholders of DWS International Equity Fund--Institutional
Class ("Institutional Fund"), a series of DWS Institutional Funds
("Institutional Trust"), in a proposed reorganization of the Fund with the
Institutional Fund. However, at a meeting of the Board of Trustees of the
Institutional Trust ("Board") on June 27, 2006, the Board approved the
liquidation of the Institutional Fund, rather than the reorganization.
Accordingly, the Trust respectfully submits that the withdrawal of the
post-effective amendments to the Registration Statement is consistent with the
public interest and the protection of investors.
Any questions or comments on this request should be directed to the undersigned
at (617) 295-2565.
Very truly yours,
/s/ Caroline Pearson
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Caroline Pearson
Enclosures
cc: John Greskiewicz
Dianne O'Donnell, Willkie Farr & Gallagher LLP
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