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February 17, 2005

VIA EDGAR

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

         Re:    J.P. Morgan Mutual Fund Select Group (the "Trust")
                (File Nos. 333-13317/811-07843)
                Withdrawal of Post-Effective Amendment No. 28

Ladies and Gentlemen:

         Pursuant to Rule 477(a) under the Securities Act of 1933, the Trust
requests withdrawal of Post-Effective Amendment No. 28 to the Trust's
registration statement on Form N-1A. Post-Effective Amendment No. 28 was filed
via EDGAR on December 17, 2004 (Accession No. 0001047469-04-037616) for the
purpose of updating certain financial information and updating disclosures
regarding market timing, breakpoints and certain other topics in accordance with
the rules under the Investment Company Act of 1940. Since Post-Effective
Amendment No. 28 was filed on December 17, 2004, shareholders of each series of
the Trust included in Post-Effective Amendment No. 105 have met and each such
series of the Trust has approved either a merger or shell reorganization
transaction pursuant to which each of the respective series will be reorganized
effective after the close of business on February 18, 2005. As a result of those
transactions, the forms of prospectuses and statements of additional information
included in Post-Effective Amendment No. 28 will no longer be required.

     As a result, the Trust is requesting withdrawal of Post-Effective Amendment
No. 28 to the Trust's registration statement. The Trust confirms that it has not
sold any shares using the forms of prospectuses included in Post-Effective
Amendment No. 28.

         If you have any questions regarding this request, please call me at
212.837.1711.

Sincerely,

/s/ Avery P. Maher
- -------------------------
Avery P. Maher
Assistant Secretary
J.P. Morgan Mutual Fund Select Group

<Page>


February 17, 2005

VIA EDGAR

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

         Re:    J.P. Morgan Mutual Fund Select Group (the "Trust")
                (File Nos. 333-13317/811-07843)
                Withdrawal of Post-Effective Amendments Nos. 27, 29 and 31

Ladies and Gentlemen:

     Pursuant to Rule 477(a) under the Securities Act of 1933, the Trust
requests the withdrawal of Post-Effective Amendment No. 27 (filed as a 485APOS
on October 29, 2004 -- Accession No. 0001047469-05-001360), Post-Effective
Amendment No. 29 (filed as a 485BXT on December 28, 2004 -- Accession No.
0001047469-04-038444), and Post-Effective Amendment No. 31 (filed as a 485BXT on
January 24, 2005 -- Accession No. 0001047469-04-032486) to the Trust's
Registration Statement on Form N-1A (together, the "Amendments"). Post-Effective
Amendment No. 27 was filed for the purpose of registering an additional share
class to round out product offerings. Post-Effective Amendments Nos. 29 and 31
were filed solely for the purpose of extending the effective date of
Post-Effective Amendment No. 27.

         Since the Amendments were filed, the determination has been made not to
offer the share class being registered in the Amendments. As a result, the Trust
is requesting withdrawal of the Amendments. The Trust confirms that it has not
sold any shares using the form of prospectus included in the Amendments.

         If you have any questions regarding this request, please call me at
212.837.1711.

Sincerely,

/s/ Avery P. Maher
- ------------------------
Avery P. Maher
Assistant Secretary
J.P. Morgan Mutual Fund Select Group