KEYCO BOND FUND, INC.
27777 Franklin Road, Suite 1630
Southfield, MI  48034
248/353-0790

Online Filing

May 26, 2017



U.S. Securities and Exchange Commission
Division of Investment Management
Office of the Chief Accountant
100 F Street, NE
Washington, DC  20549

Attention:  	Jeffrey W. Long
	Staff Accountant

Ladies and Gentlemen:

Re:	Keyco Bond Fund, Inc. Form N-CSR for the year ended
September 30, 2016 filed November 29, 2016

On behalf of Keyco Bond Fund, Inc. (the  Company ), the
information in this letter is being furnished in response
to the verbal comments received by Ms. Carol Singer on
behalf of the Company from the staff of the Securities
and Exchange Commission via telephone on May 1, 2017.

Form N-CSR for the year ended September 30, 2016

A footnote in the audited financial statements reports
that the Company changed its accounting methods for
revenue recognition as of October 1, 2015.

The SEC has asked:

What steps did the Company take to decide that the change
was a change of accounting method rather than a correction
of an error?

Response:

Keyco Bond Fund, Inc. is a relatively small closed-end
municipal bond fund.  Its primary investment objective has
always been to earn as high a level of current income
exempt from federal income taxes as is available from
municipal bonds, consistent with prudent investment
management and preservation of capital.

In pursuing its objective, the Company has invested in
municipal bonds with relatively immaterial amounts of bond
premium or bond discount.  The Company had been unable to
locate computer software that was cost-effective for
calculating bond premium amortization and discount
accretion.  Therefore, the Company recognized these
relatively immaterial amounts of premium and discount
at the disposal of the bonds.  The Company has never
considered this to be an error.




U.S. Securities and Exchange Commission
May 26, 2017
Page 2


In late 2015, the Company became aware of cost-effective
software that could perform the monthly amortization and
accretion calculations using the effective-yield method.
At that time a decision was made to change the Company s
methods of accounting for the bond premium and discount
to the preferred accounting method.

Because the Company has always considered the premium and
discount amounts on the bonds it purchased to be
immaterial, the Company views the accounting changes made
to be changes in accounting methods rather than a
correction of an error.  The Company s auditors have
concurred with this point of view and have been an
additional impetus to move to the preferred accounting
treatment.

If you have any questions or comments concerning the
response of the Company to the comments of the staff,
please contact me at (248) 353-0790.

Very truly yours,

KEYCO BOND FUND, INC.

/s/ Joel D. Tauber

Joel D. Tauber
President


cc:	Board of Directors of Keyco Bond Fund, Inc.
	Carol Singer, for Keyco Bond Fund, Inc.