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