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 20, 2008 BY EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Narragansett Insured Tax-Free Income Fund (CIK 0000888955) Registration Statement on Form N-14 (No. 333-153073) Ladies and Gentlemen: On behalf of Narragansett Insured Tax-Free Income Fund, CIK 0000888955 (the "Fund"), and pursuant to Rule 477 under the Securities Act of 1933, this letter constitutes application to withdraw Registration Statement No. 333-153073 on Form N-14, filed with the Commission yesterday, August 19, 2008 (Accession No. 0000888955-08-000023). This Registration Statement was intended to be a pre-effective amendment to a registration statement filed on behalf of the Fund on July 11, 2008 and was inadvertently filed yesterday on Form N-14 instead of Form N-14/A. The pre-effective amendment was subsequently properly filed on Form N-14/A and is being reviewed. Therefore, it is appropriate to withdraw Registration Statement No. 333-153073. 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