Steve Suleski
Vice President
Office of General Counsel
Phone:   608.231.7653
Fax:     608.236.7653
E-mail:  steve.suleski@cunamutual.com

November 4, 2005

SENT VIA EDGAR

Mr. Tony Burak
U.S. Securities and Exchange Commission
Division of Investment Management
100 F. Street NE
Washington, D.C.  20549

Re:      Ultra Series Fund ("USF") File No. 811-4815

Dear Mr. Burak:

This is in response to our telephone conversation on Friday, October 7, 2005.

Set forth below are the Ultra Series Fund's responses to each item noted during
our conversation. For your convenience and ease of review, we have restated each
comment, and provided our response immediately thereafter.

ITEM NO. 1: In the Schedule of Investments, under the Bond Fund, include
interest rate and maturity date for the euro dollars going forward.

RESPONSE NO. 1: The security we held in the Bond Fund had an interest rate of
1.2% and matured on January 3, 2005. We have adjusted our disclosure procedures
accordingly to include the interest rate and maturity date on this and similar
securities in the Schedules of Investments.

ITEM NO. 2: In the Statement of Assets & Liabilities, under the Foreign Tax
Reclaim for the High Income Fund, the amount of $3,880 stated since December,
2002 has not been collected. We should include an explanation in the notes as to
if this is collectable or not.

RESPONSE NO. 2: We have reviewed our analysis of the Foreign Tax Reclaim for the
High Income Fund and continue to believe that this item was and is collectible.
Because of the nature of the process, our past experience has been that it can
take well over two years to collect on the Reclaim. In the future, any
discussion of the Foreign Tax Reclaim will include a statement as to its
collectibility in the financial statements.

ITEM NO. 3: In the Financial Statement Notes, we should include a "discussion"
paragraph on the Valuation Policy, for shares of open-end mutual funds (ex.
shares are valued at NAV each day) that is currently in place.



Mr. Tony Burak
November 4, 2005
Page 2


RESPONSE NO. 3: The following valuation policy is currently in our Statement of
Additional Information dated May 2, 2005, page 49. We will reflect this
information in our Financial Statement Notes going forward.

Valuing Shares of open-end investment companies - Investments in shares of
open-end mutual funds are valued at their daily net asset value (NAV) which is
calculated as of 3:00 p.m. Central Time on each day on which the New York Stock
Exchange is open for business. NAV per share is determined by dividing each
fund's total net assets by the number of shares of such fund outstanding at the
time of the calculation. Total net assets are determined by adding the total
current value of portfolio securities, cash, receivables, and other assets and
subtracting liabilities. Shares will be sold and redeemed at the NAV per share
next determined after receipt in good order of the purchase order or request for
redemption.

ITEM NO. 4: Need to amend current Form NCSR to reflect the correct filing number
on the cover page.

RESPONSE NO. 4: We filed the amended NCSR filing dated December 31, 2004.

ITEM NO. 5: On Form NCSR we inadvertently attached the Disclosure Procedures vs.
the Code of Ethics for Sarbanes Oxley.

RESPONSE NO. 5: We filed the amended NCSR filing dated December 31, 2004 and
included the Sarbanes Oxley Code of Ethics.

ITEM NO. 6: Include Item #9 "Submission of Matters to a Vote of Security
Holders" in the NCSR amendment filing.

RESPONSE NO. 6: We filed the amended NCSR filing and included Item #9
"Submission of Matters to a Vote of Security Holders". We stated that there were
no material changes for the fiscal year ended December 31, 2004.

ITEM NO. 7: Revise the 302 Certification pages and include in the NCSR amendment
filing as required by Rule 30a-2(a) under the Act.

RESPONSE NO. 7: The revised 302 Certification pages are included in the amended
NCSR filing dated December 31, 2004.

In making this response, the fund acknowledges:
         o  the fund is responsible for the adequacy and accuracy of the
            disclosure in filings;
         o  staff comments or changes to disclosure in response to staff
            comments in the filings reviewed by the staff do not foreclose the
            Commission from taking any action with respect to the filing; and
         o  the fund may not assert staff comments as a defense in any
            proceedings initiated by the Commission or any person under the
            federal securities laws of the United States.

Please give me a call if you have any questions.

Very truly yours,

/s/ Steve Suleski
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Steve Suleski