[LOGO OF CITIGROUP] Global Transaction Services corporate and Two Portland Square investment banking Portland, ME 04101 Tel. 207 879 1900 Fax 207 822 6677 April 25, 2006 VIA EDGAR AND U.S. MAIL Mr. Keith O'Connell Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: ICM Series Trust (File 33-4081; 811-8507 Post-Effective Amendment No. 11 to Registration Statement on Form N-1A Filed on March 2, 2006 (the "Registration Statement") Dear Mr. O'Connell: This letter is to confirm that the above-referenced Registration Statement was filed pursuant to Rule 485(a) under the Securities Act of 1933, as amended, with an intended effective date of May 1, 2006. Although the facing sheet to the Registration Statement correctly indicated that the filing was made pursuant to Rule 485(a), it incorrectly listed March 2, 2006 as the effective date. As we have discussed, the intended effective date is May 1, 2006. * * * * * If you have any questions regarding the matters discussed above, please feel free to call me at (207) 822-6116. Sincerely, /s/ Margaret Gallardo-Cortez --------------------------------- Margaret Gallardo-Cortez Senior Vice President and Counsel