December 16, 2004

VIA ELECTRONIC TRANSMISSION

Securities and Exchange Commission
Division of Investment Management
450 Fifth Street, N.W.
Washington, D.C. 20549


         RE:      CCMI Funds, File No. 33-45753 and 811-06561

Ladies and Gentlemen:

         On behalf of the CCMI Equity Fund, the CCMI Bond Fund, and the CCMI
Tax-Exempt North Carolina Bond Fund (the "Funds"), each a series of CCMI Funds
(the "Trust"), and Unified Financial Securities, Inc. the Fund's distributor, we
hereby request that the Commission accelerate the effective date of
Post-Effective Amendment No. 24 to the Trust's Registration Statement (the
"Amendment) to December 30, 2004, or the earliest practicable date thereafter.

         The Amendment was filed on December 13, 2004 pursuant to Rule 485(a)
promulgated under the Securities Act of 1933 to provide disclosure regarding the
Funds' proposed new investment adviser, the Trust's market timing, valuation and
selective disclosure policies, and other updating information. Absent
acceleration, the Amendment would become effective on February 11, 2005.

         If you have any questions concerning this request please contact
Michael V. Wible at (614) 469-3297.



Unified Financial Securities, Inc.                   CCMI Funds



By:/s/ Stephen D. Highsmith, Jr.                     By: /s/ Anthony J Ghoston
   -----------------------------                        -----------------------
       Stephen D. Highsmith, Jr.                         Anthony J. Ghoston
       President                                         President