Conseco Fund Group
                         11815 North Pennsylvania Street
                              Carmel, Indiana 46032


April 4, 2002


VIA EDGAR
- ---------

U.S. Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC  20549

    Re:   Conseco Fund Group - CIK No. 0001023658
          -- Conseco Small-Cap Growth Fund
          -- Conseco Large-Cap Value Fund
          1933 Act File No. 333-13185
          1940 Act File No. 811-07839
          Post-Effective Amendment No. 18 - Application for Withdrawal
          ------------------------------------------------------------

Ladies and Gentlemen:

     On behalf of  Conseco  Fund  Group (the  "Registrant"),  I hereby  request,
pursuant  to Rule  477  under  the  Securities  Act of  1933,  as  amended,  the
withdrawal of Post-Effective  Amendment No. 18 to the Registrant's  registration
statement on Form N-1A filed with the U.S. Securities and Exchange Commission on
January 11, 2002. The Fund has  determined not to proceed with the offering.  No
securities were sold in connection with the offering.

     If you have any questions  regarding  this matter,  please  contact  Fatima
Sulaiman,  Esq. of  Kirkpatrick  & Lockhart  LLP,  counsel to the Fund, at (202)
778-9223.


                                  Sincerely,

                                  /s/ William P. Kovacs
                                  ---------------------

                                  William P. Kovacs
                                  Vice President and Secretary


cc:   Fatima Sulaiman, Esq.
      Kirkpatrick & Lockhart LLP

      Houghton R. Hallock, Jr.
      Securities and Exchange Commission
      Via Facsimile 202/628-9002