KAYNE ANDERSON MUTUAL FUNDS
                       1800 AVENUE OF THE STARS, STE. 200
                              LOS ANGELES, CA 90067
                                  (310)556-2721

VIA EDGAR

                                November 13, 1999


Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549-1004

     Re: Kayne Anderson Mutual Funds
         File Nos. 333-08045 and 811-07705

Dear Sir/Madam:

     On behalf of Kayne  Anderson  Mutual  Funds  (the  "Registrant"),  I hereby
submit this application for withdrawal of Post-Effective  Amendment No. 8 to the
Registrant's  Registration  Statement on Form N-1A (the "Amendment") pursuant to
Rule 477(a) of the Securities Act of 1933 (the "Act").

     The  Amendment  was  filed to  notify  of a  material  change  to the Kayne
Anderson Intermediate Tax-Free Bond Fund's fundamental investment objective. The
Amendment  is  being  withdrawn  because  the  Registrant  was  notified  by the
Securities and Exchange  Commission that this should have been filed pursuant to
Rule 497. A supplement updating the Prospectus pursuant to Rule 497 was filed on
November 8, 1999.

     The Amendment  will become  effective on November 20, 1999 pursuant to Rule
485(a) of the Act.  Please issue an order with respect to this  application  for
withdrawal as soon as possible.

     Pursuant to the  requirements of Rule 478 of the Act, this  application for
withdrawal  of the  Amendment  has been  duly  signed  by the  President  of the
Registrant this 12th day of November, 1999.

                               Very truly yours,

                               Allan Michael Rudnick
                               President