CERTIFICATION
Pursuant to Section 302 of the
Sarbanes-Oxley Act of 2002

I, John J. Kelley, certify that:

1.       I have reviewed this report on Form N-CSR of the 1838 Bond-Debenture
         Trading Fund;

2.       Based on my knowledge, this report does not contain any untrue
         statement of a material fact or omit to state a material fact necessary
         to make the statements made, in light of the circumstances under which
         such statements were made, not misleading with respect to the period
         covered by this report;

3.       Based on my knowledge, the financial statements, and other financial
         information included in this report, fairly present in all material
         respects the financial condition, results of operations, changes in net
         assets, and cash flows (if the financial statements are required to
         include a statement of cash flows) of the registrant as of, and for,
         the periods presented in this report;

4.       The registrant's other certifying officer and I are responsible for
         establishing and maintaining disclosure controls and procedures (as
         defined in Rule 30a-3(c) under the Investment Company Act of 1940) and
         internal control over financial reporting (as defined in Rule 30a-3(d)
         under the Investment Company Act of 1940) for the registrant and have:

         a) Designed such disclosure controls and procedures to ensure that
            material information relating to the registrant, including its
            consolidated subsidiaries, is made known to us by others within
            those entities, particularly during the period in which this report
            is being prepared;

         b) Designed such internal control over financial reporting, or caused
            such internal control over financial reporting to be designed under
            our supervision, to ensure that material information relating to the
            registrant, including its consolidated subsidiaries, is made known
            to us by others within those entities, particularly during the
            period in which this report is being prepared;

         c) Evaluated the effectiveness of the registrant's disclosure controls
            and procedures, and presented in this report our conclusions about
            the effectiveness of the disclosure controls and procedures, as of a
            date within 90 days prior to the filing date of this report based on
            such evaluation; and

         d) Disclosed in this report any change in the registrant's internal
            control over financial reporting that occurred during the
            registrant's most recent fiscal half-year that has materially
            affected, or is reasonably likely to materially affect, the
            registrant's internal control over financial reporting.

5.       The registrant's other certifying officer and I have disclosed to the
         registrant's auditors and the audit committee of the registrant's board
         of directors (or persons performing the equivalent functions):

         a) All significant deficiencies and material weaknesses in the design
            or operation of internal control over financial reporting which are
            reasonably likely to adversely affect the registrant's ability to
            record, process, summarize, and report financial information; and

         b) Any fraud, whether or not material, that involves management or
            other employees who have a significant role in the registrant's
            internal control over financial reporting.


         /s/ John J. Kelley                          Date: November 22, 2004
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         John J. Kelley
         Vice President and Secretary
         (Principal Financial Officer)