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 August 19, 2008 BY EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Narragansett Insured Tax-Free Income Fund Registration Statement on Form N-14 (Registration Statement No. 333-152299) Pre-Effective Amendment No. 2 on Form N-14/A Dear Sirs: On behalf of Narragansett Insured Tax-Free Income Fund (the "Fund"), we are filing today with the Commission pursuant to Rule 472 under the Securities Act of 1933 and in response to comments received from the Commission by telephone on August 6, 2008, Pre-Effective Amendment No. 2 to Form N-14 Registration Statement on Form N-14/A of the Fund. On behalf of the Fund, we hereby request that the effective date of the Registration Statement be accelerated to 10:00 a.m. on August 20, 2008 or as soon thereafter as practicable. We inadvertently filed this Pre-Effective Amendment earlier today on Form N-14 instead of Form N-14/A. Please treat the earlier filing as withdrawn and review the current filing on Form N-14/A. Please contact me or my partner Robert Jones at the above telephone number, 212-818-1110, with any questions. Very truly yours, /s/ Arthur Dudley II Arthur Dudley II