BMC Fund, Inc.
800 Golfview Park
P. O. Box 500
Lenoir, NC 28645
828-758-6100 ext. 122

September 20, 2012

VIA EDGAR

Mr. Jeff Long
Staff Accountant
U. S. Securities and Exchange Commission
Office of Disclosure and Review
100 F Street, NE
Washington, DC 20549

Dear Mr. Long:

This is in response to the August 28, 2012 Sarbanes-Oxley
telephone review of BMC Fund, Inc. (the "Fund").

Statement of Assets and Liabilities: You indicated any
payables to the Fund's directors, trustees or affiliates
should be shown separately, in accordance with
Regulation S-X Reg. 210.6-04, Item 12 (other
liabilities).In all future reports to shareholders,
the Fund will state separately all other liabilities,
if any, in accordance with Regulation S-X
Reg. 210.6-04, Item 12.

Investments in Other Mutual Funds - Share Classes: As
discussed, the Fund invests in various share classes
of other mutual funds. You inquired about the Fund's
policy for choosing a share class to invest in. The
Fund buys the most economical share class available
based on the dollar amount of the purchase.

Investments in Other Mutual Funds - Distribution Fees:
When the Fund invests in mutual funds that pay
distribution fees, the fees are paid back to the Fund.

Board of Directors: In all future reports to shareholders,
the Fund will disclose the Term of Office for its board
members.

Statement of Operations - Income: As of October 31, 2011,
equity in losses of wholly-owned subsidiary ($670)
represented the final expenses associated with the
dissolution of the wholly-owned subsidiary as follows:
rent expense $140, airplane expense $500, taxes and
licenses $30. The wholly-owned subsidiary owned an
aircraft. Following the sale of the aircraft,
the entity was dissolved on February 28, 2011.

Statement of Changes in Net Assets - Retained Earnings
Prior to Becoming An Investment Company: As discussed,
the Fund was originally a part of Broyhill Furniture
Industries (the "Company"), which was sold in 1980. At the
time of the sale, a provision in the tax law allowed a
portion of the cash, real estate and other holdings of the
Company to be rolled into a regulated investment company
("RIC"). Some of the retained earnings rolled over prior
to the formation of the RIC.

In addition to the Fund's responses to your comments during
our telephone conversation on August 28, 2012, the Fund
represents the following:

-The Fund is responsible for the adequacy and accuracy
of the disclosure in the filings;

-Staff comments or changes to disclosure in response to
staff comments in the filings reviewed by the staff do
not foreclose the Commission from taking any action with
respect to the filing; and

-The Fund may not assert staff comments as a defense in
any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

It is our understanding that the Commission's Division of
Enforcement has access to all information provided by the
Fund.

We appreciate this opportunity to improve the Fund's SEC
filings. Please contact me with questions or comments.

Sincerely,


/s/Carol Frye
Secretary and Treasurer