PEAR TREE FUNDS

December 5, 2016

VIA EDGAR

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attention:Anu Dubay, Senior Counsel

Re:         Pear Tree Funds

Request for Withdrawal of Post-Effective Amendments filed on December 2, 2016

File Nos. 333-102055, 811-03790

Accession Nos.  0000722885-16-000152

0000722885-16-000153

0000722885-16-000156

Ladies and Gentlemen:

On behalf of Pear Tree Funds, a Massachusetts business trust (the "Registrant"), we hereby request, pursuant to Rule 477 under the Securities Act of 1933, as amended (the "Securities Act"), that Post-Effective Amendment No. 60 to the Registration Statement on Form N-1A, together with all copies thereof and all exhibits and amendments thereto as originally filed by the Registrant with the Securities and Exchange Commission (the "Commission") on December 2, 2016 (the "Amendment"), be withdrawn effective immediately.

The Registrant is seeking withdrawal of the Registration Statement because of certain errors that occurred during the filing of the Amendment.  The Amendment has not become effective, and none of the Registrant's securities has been sold pursuant to the Amendment.  There were no fees paid, or required to be paid, upon the filing of the Amendment.

The Registrant requests that the Commission consent to this application on the grounds that the withdrawal of the Amendment is consistent with the public interest and the protection of investors, as contemplated by Rule 477(a) under the Securities Act.

Please send copies of the written order granting withdrawal of the Registration Statement to John Hunt, Sullivan & Worcester LLP, counsel to the Registrant, via email at jhunt@sandw.com.

Should you have any questions regarding this matter, please contact John Hunt at (617) 338-2961 or, in his absence, Jeffrey Moreland at (617) 338-2818.

Very truly yours,

/s/    Willard L. Umphrey

Willard L. Umphrey

President

cc (via e-mail):

Deborah A. Kessinger, Esq. – Pear Tree Advisors, Inc.

John Hunt, Esq. – Sullivan & Worcester LLP

Jeffrey B. Moreland, Esq. - Sullivan & Worcester LLP