[FAF ADVISORS LOGO]

800 Nicollet Mall                                          KATHLEEN L. PRUDHOMME
BC-MN-H05F                                                DEPUTY GENERAL COUNSEL
Minneapolis, MN 55402                                Direct line: (612) 303-3738
                                                            Fax:  (612) 303-4223


May 25, 2006


Mr. Kevin Rupert
Division of Investment Management
Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549

    Re: First American Funds, Inc. (SEC File No. 811-03313) ("FAF")
        First American Investment Funds, Inc. (SEC File No. 811-05309) ("FAIF")
        First American Strategy Funds, Inc. (SEC File No. 811-07687) ("FASF")
        Shareholder Reports for the Fiscal Years Ended August 31, 2005 (FAF and
        FASF) and September 30, 2005 (FAIF)

Dear Mr. Rupert:

     The following is in response to your comments that we discussed last week
regarding the above-referenced shareholder reports of FAF, FAIF and FASF
(together, the "Funds"):

1.   FOR FAIF AND FAF, THE NOTE TO THE FINANCIAL STATEMENTS REGARDING SECURITIES
LENDING SHOULD BE REVISED TO CLARIFY THAT SECURITIES LENDING COLLATERAL IS
INVESTED ONLY IN MONEY- MARKET -ELIGIBLE SECURITIES.

     Going forward, the note to the financial statements which details the
investment of cash collateral will contain the following sentence: "Cash
collateral is invested in short-term, high quality U.S. dollar-denominated
securities that would be eligible for investment by a money market fund under
Investment Company Act Rule 2a-7."

2.   MULTIPLE BENCHMARKS ARE LISTED FOR EACH SERIES OF FASF. ONE BENCHMARK
SHOULD BE DESIGNATED THE PRIMARY BENCHMARK FOR EACH SERIES.

     In future annual reports, and in updated prospectuses, one benchmark will
be designated as the primary benchmark for each series of FASF.

3.   IN APPROVING THE ADVISORY CONTRACT FOR FASF, DID THE BOARD OF DIRECTORS
TAKE INTO ACCOUNT THE PROFITABILITY OF THE UNDERLYING FUNDS?

     The contract review process for FASF and for the underlying funds takes
place at the same time. During this process, the Board looked at the
profitability of each underlying fund individually as well as the profitability
of each series of FASF. This will be noted in future shareholder reports that
discuss approval of FASF's advisory agreement.



[FAF ADVISORS LOGO]


4.   NOTE 3 TO THE FINANCIAL STATEMENTS OF FAF NOTES THAT THERE WAS A CHANGE IN
THE CONTRACTUAL FEE WAIVER FOR PIPER JAFFRAY CLASS SHARES THAT WENT INTO EFFECT
JUNE 6, 2005. HOW WAS THIS CHANGE IMPLEMENTED?

     The Board of Directors approved this change in contractual fee waivers at a
meeting held May 4, 2005. Holders of Piper Jaffray Class shares were notified of
this change by a prospectus supplement dated May 12, 2005 (filed with the
Securities and Exchange Commission on May 12, 2005, Accession No.
0000897101-05-001182).

     In connection with the receipt of the foregoing comments from the staff of
the Securities and Exchange Commission (the "Commission") with respect to the
above-referenced filings, the Funds hereby acknowledge that:

     1.   The Funds are responsible for the adequacy and accuracy of the
          disclosure in the filing.

     2.   Staff comments or changes to disclosure in response to staff comments
          in the filing reviewed by the staff do not foreclose the Commission
          from taking any action with respect to the filing.

     3.   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.


                                                     Very truly yours,

                                                     /s/ Kathleen L. Prudhomme

                                                     Kathleen L. Prudhomme
                                                     Deputy General Counsel