December 15, 1999

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn:    Ms. Laura J. Riegel
         Division of Investment Management

         Re:      Withdrawal of Post-Effective Amendment No. 4
                  to the Registration Statement under the Securities
                  Act of 1933 of Kemper Funds Trust
                  File Nos. 333-65661 and 811-09057
                  ---------------------------------

Dear Ms. Riegel:

         Pursuant to Rule 477(a) under the Securities Act of 1933, as amended
(the "1933 Act"), Kemper Funds Trust (the "Trust") hereby applies to withdraw
Post-Effective Amendment No. 4 to its registration statement under the 1933 Act
that was filed on October 3, 1999 (the "Amendment"). The Amendment was filed for
the purpose of adding a new series to the Trust, namely Kemper Equity Fund (the
"Fund"). At this time, the Trust has determined that the Fund does not comport
with its immediate business plans, although it may pursue registration of
similar series in the future. The Trust states that it has never made a public
offering of securities of the Fund; that the Fund is not now nor has it ever
been active; and that the Fund has no assets, known liabilities or pending
claims. The Trust believes that withdrawal of this Amendment would be consistent
with the public interest and the protection of investors.

         Please contact the undersigned at 617.295.2561 with any questions you
may have concerning the foregoing.

                                Very truly yours,

                                /s/Maureen Kane
                                Maureen Kane
                                Assistant Secretary
                                Kemper Funds Trust