Morgan, Lewis & Bockius LLP                                         MORGAN LEWIS
1701 Market Street
Philadelphia, PA  19103-2921
Tel:  215.963.5000
Fax:  215.963.5001
www.morganlewis.com

JOHN J. O'BRIEN
PARTNER
215.963.4969


January 27, 2016


FILED AS EDGAR CORRESPONDENCE



Ms. Amy W. Miller
Senior Counsel
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549


Re:  Response letter to comments on Pre-Effective Amendment No. 1 to the
     Registration Statement on Form N-1A of The Community Development Fund (File
     Nos. 333-206012 and 811-23080)
     ---------------------------------------------------------------------------

Dear Ms. Miller:

Set forth below are your comments (as provided via teleconference on October 21,
2015), and our responses to those comments, on Pre-Effective Amendment No. 1 to
the Registration Statement on Form N-1A of The Community Development Fund (the
"Fund") filed under the Investment Company Act of 1940, as amended (the "1940
Act"), and the Securities Act of 1933, as amended (the "1933 Act"), with the
Securities and Exchange Commission ("SEC") on October 14, 2015, regarding the
registration of shares of the Fund. Unless otherwise noted, capitalized terms
have the same meaning as contained in the Prospectus and/or Statement of
Additional Information included in the Registration Statement.

1.   COMMENT: Please complete the fee table and expense example set forth in
     the "Fees and Expenses" section.

     RESPONSE: In response to your comment, we have completed the fee table and
     expense example, as set forth in Pre-Effective Amendment No. 2, as filed
     shortly after this Correspondence filing.

2.   COMMENT: In the second footnote to the "Annual Fund Operating Expenses"
     table, please revise the list of excluded expenses to include all excluded
     expenses listed in the Fund's Expense Limitation Agreement.

     RESPONSE: In response to your comment, we have revised the list of excluded
     expenses to include all excluded expenses listed in the Fund's Expense
     Limitation Agreement.



3.   COMMENT: In the Fund's principal investment strategy, please describe
     supplementally the extent to which the Fund expects to invest in
     certificates of deposit.

     RESPONSE: The Fund currently expects to invest in certificates of deposit
     to provide some investment return while awaiting CRA investment
     opportunities. The Fund does not currently expect to invest in certificates
     of deposit in a material amount.

4.   COMMENT: Please confirm supplementally whether the Fund will be marketed
     to individual investors.

     RESPONSE: Although certain individual investors may purchase shares of the
     Fund due to a pre-existing relationship with the principal of the Fund's
     investment adviser or to support the community investment nature of the
     Fund's portfolio, the Fund is primarily intended for banking entities
     subject to the Community Reinvestment Act and the Fund does not currently
     expect to market shares to retail investors.

5.   COMMENT: Please provide the Fund's Financial Statements.

     RESPONSE: The Fund's Financial Statements have been provided in
     Pre-Effective Amendment No. 2, as filed shortly after this Correspondence
     filing.

I hereby acknowledge on behalf of the Fund that: (i) the Fund is responsible for
the adequacy and accuracy of the disclosure in its registration statement; (ii)
SEC Staff comments or changes to disclosure in response to Staff comments in the
registration statement reviewed by the Staff do not foreclose the SEC from
taking any action with respect to the registration statement; and (iii) if, to
the Fund's knowledge, an inquiry or investigation is currently pending or
threatened by the SEC and if the SEC subsequently, in order to protect its
investigative position, so requests, the Fund will not assert SEC Staff comments
with respect to the inquiry or investigation as a defense in any proceeding
initiated by the SEC under the federal securities laws of the United States.

As indicated in the SEC's June 24, 2004 release regarding the public release of
comment letters and responses, you are requesting such acknowledgements from all
companies whose filings are being reviewed and this request and these
acknowledgements should not be construed as suggesting that there is an inquiry
or investigation or other matter involving the Fund.

If you have any questions, need any additional information or would like any
clarification, please contact me at (215) 963-4969.

Very truly yours,

/s/ John J. O'Brien
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John J. O'Brien