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



                               December  21, 2006



BY EDGAR

U.S. Securities and Exchange Commission
Mr. John Grzeskiewicz
100 F Street, NE
Washington, DC 20549


     RE:   MEMBERS MUTUAL FUNDS
           POST-EFFECTIVE AMENDMENT NO. 17 TO REGISTRATION STATEMENT
           ON FORM N-1A, FILE NOS. 333-29511; 811-08261

Dear Commissioner:

   On behalf of MEMBERS Mutual Funds (the "Fund"), I am providing the Fund's
   response to your comments provided by telephone to Cynthia Reid of Sutherland
   Asbill & Brennan LLP on December 21, 2006 with regard to Post-Effective
   Amendment No. 17 to the above-referenced registration statement.

   Set forth below is your comment on Post-Effective Amendment No. 17.  The
   Fund's response follows each comment.

   1.  PLEASE ADD THE UPDATED INFORMATION IN THE FEE TABLE AND FAX TO ME.

       The fee table was faxed to the Staff and incorporated into our
       Post-Effective Amendment No. 19.

   2.  ACKNOWLEDGEMENTS

       The disclosure in the Registration Statement is the responsibility of the
       Fund. The Fund acknowledges that any action of the Securities and
       Exchange Commission (the "Commissioner"), or its staff acting pursuant to
       delegated authority, in declaring the Registration Statement effective,
       or accelerating the effective date thereof, does not relieve the Fund
       from its full responsibility for the adequacy and accuracy of the
       disclosures therein. The Fund also represents to the Commission that
       should the Commission or its staff declare the Registration Statement
       effective or accelerate the effective date thereof, the Fund will not
       assert this action as a defense in any proceeding initiated by the
       Commission under the federal securities laws of the United States.

                                   *   *   *

I hope you find these responses satisfactory.  If you have any questions or
further comments regarding this Amendment, please call me at 608-231-7653.


                                            Sincerely,

                                            /s/Steve Suleski

                                            Steve Suleski, Esq.


CC:  Cynthia Reid, Esq.