BUTZEL LONG, a professional corporation 380 Madison Avenue, 22nd Floor New York, NY 10017 Tel: (212) 818-1110 FAX: (212) 818-0494 e-mail: dudleya@butzel.com July 11, 2008 BY EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Narragansett Insured Tax-Free Income Fund File Nos. 33-48696 and 811-6707 Dear Sirs: On behalf of Narragansett Insured Tax-Free Income Fund (the "Fund"), we are filing today with the Commission pursuant to Rule 402 under the Securities Act of 1933 and pursuant to Rule 8b-11 under the Investment Company Act of 1940, Form N-14 Registration Statement of the Fund. It is proposed that this amendment will become effective on August 11, 2008. Please provide comments to me or to my partner Robert Jones at the above telephone number, 212-818-1110. Very truly yours, /s/ Arthur Dudley II Arthur Dudley II