VIA EDGAR CORRESPONDENCE


March 10, 2005



Mr. Kevin C. Rupert
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

Mr. Rupert:

We received your correspondence regarding the Form N-CSR filed on behalf of
Viking Mutual Funds on March 1, 2005, which was missing Item 22(d)(1)
disclosure.  We have revised and re-filed the N-CSR, complying with all Item
22 provisions and completing new SOX certifications.  We double-checked the
disclosed sales loads and the inception points for the line graphs and also
checked the total returns per your request.  The sales loads were correct.
The inception points for the line graphs were off by $1.00 on each Fund and
have been corrected.  The total returns were correct.   The revised annual
shareholder reports have been printed and will be mailed on March 11.  The
adviser, Viking Fund Management, LLC, is paying all costs associated with
printing and mailing.  The error was simply an oversight and should not have
happened.  That being said, we are a very small operation (four employees)
and it has been a busy time for us with our 485APOS filing made on February
25.  Additionally, I was unexpectedly called out of town for a week in mid-
February for an adoption placement.  We have taken steps to ensure accurate
and timely filing of required information to the SEC and delivery of such
information to shareholders in the future.  Specifically, Viking Mutual
Fund's disclosure controls and procedures have been amended to address a
review of all current instructions, rules and regulations in conjunction with
the review of Form N-CSR prior to filing.

Viking Mutual Funds acknowledges that it is responsible for the adequacy and
accuracy of the disclosure in the filings; staff comments or changes to
disclosure in response to staff comments in the filings reviewed by the staff
do not foreclose the Commission from taking any action with respect to the
filing; and the Funds may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

If you have any questions or comments you can reach me at 701-852-1264 or you
may contact Fatima Sulaiman of Kirkpatrick & Lockhart Nicholson Graham LLP at
202-778-9223.

Shannon D. Radke
President