Conseco Fund Group
                         11815 North Pennsylvania Street
                              Carmel, Indiana 46032




                                  May 22, 1998


EDGAR FILING
- ------------

Mr. Houghton R. Hallock, Jr.
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

      Re:   Conseco Fund Group - CIK No. 0001023658
            -- Conseco High Yield Focus Fund
            1933 Act File No. 333-13185
            1940 Act File No. 811-07839
            Post-Effective Amendment No. 5 - Application for Withdrawal
            ------------------------------------------------------------

Dear Sir:

      Pursuant  to Rule  477(a)  under the  Securities  Act of 1933,  as amended
("1933 Act"),  on behalf of Conseco Fund Group  ("Registrant"),  we respectfully
withdraw  Post-Effective  Amendment  No.  5  to  the  Registrant's  Registration
Statement  on Form  N-1A.  Post-Effective  Amendment  No.  5 was  submitted  and
accepted on April 14,  1998  pursuant  to Rule  485(a)  under the 1933 Act.  The
effective  date of  Post-Effective  Amendment  No. 5 was to be 75 days after the
date of its filing (June 29, 1998), and currently it is pending.  Post-Effective
Amendment  No. 5 was  submitted  to reflect the  creation of a new series of the
Registrant,  the Conseco High Yield Focus Fund. Due to marketing considerations,
the  Registrant has determined not to initiate the Conseco High Yield Focus Fund
as a new series at this time. The Board of Trustees of the Registrant has passed
a  resolution  approving  this  application  for  withdrawal  of  Post-Effective
Amendment No. 5.

                                             Sincerely,                      
                                                                             
                                                                             
                                                                             
                                                                             
                                             /s/ William P. Latimer         
                                             --------------------------------
                                              William P. Latimer, Esq.       
                                                Vice President and Secretary 
                                                Conseco Fund Group           
                                             
                                   


cc:   Donald W. Smith, Esq.
        Kirkpatrick & Lockhart LLP