April 21, 2009

VIA EDGAR AND EMAIL
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U.S. Securities and Exchange Commission
Division of Investment Management
Office of Disclosure
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention:  Ms. Sheila Stout

Re:  SEI Asset Allocation Trust (File No. 811-07445)
     SEI Daily Income Trust (File No. 811-03451)
     SEI Institutional International Trust (File No. 811-5601)
     SEI Institutional Investments Trust (File No. 811-07257)
     SEI Institutional Managed Trust (File No. 811-4878)
     SEI Liquid Asset Trust (File No. 811-03231)
     SEI Tax Exempt Trust (File No. 811-03447)

Ms. Stout:

This letter  responds to comments given by you to SEI  Investments  Global Funds
Services  ("SEI"),  in its capacity as  administrator  for SEI Asset  Allocation
Trust ("SAAT"), SEI Daily Income Trust ("SDIT"), SEI Institutional International
Trust ("SIT"), SEI Institutional  Investments Trust ("SIIT"),  SEI Institutional
Managed Trust ("SIMT"), SEI Liquid Asset Trust ("SLAT") and SEI Tax Exempt Trust
("STET")  (collectively,  the "Funds") in a telephone  conversation on March 12,
2009 and a subsequent  telephone  conversation  on March 16, 2009.  The comments
relate to the SAAT March 31, 2008 annual  report to  shareholders,  SDIT January
31, 2008 annual report to shareholders, SIT and SIMT's September 30, 2008 annual
report to shareholders,  SIIT's May 31, 2008 annual report to shareholders, SLAT
June 30,  2008  annual  report to  shareholders  and STET August 31, 2008 annual
report to  shareholders,  all of which were filed on Form  N-CSR.  Additionally,
comments for the Funds also relate to the Form N-PX, filed on September 2, 2008.

SEI provides the Funds with administrative and accounting services, officers and
other  personnel,  and  submits  these  responses  on  behalf of the  Funds.  In
connection  with our  responses,  we acknowledge  that the Funds,  through their
officers and directors,  are primarily responsible for the adequacy and accuracy
of the  disclosure  in the Report.  Staff  comments or changes to  disclosure in
response to staff comments in the Report  reviewed by the staff do not foreclose
the Securities  and Exchange  Commission  ("Commission")  from taking any action
with respect to the Report. Furthermore, 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.

We have  reproduced  the  substance  of your  comments  below,  followed  by our
response.

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SEC COMMENT 1
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Managements  Discussion  of Fund  Performance  ("MDFP"), All Funds -- SEI should
consider  enhancing the MDFP disclosure,  as the language for each specific fund
is very similar, if not identical,  to other funds presented within a particular
report. SEI should discuss the techniques and strategies specific to each of the
Funds in the MDFP.

SEI RESPONSE TO COMMENT 1
SEI  AGREES AND IS  DEVELOPING  A PROCESS TO  ENHANCE  THE MDFP  DISCLOSURE  AND
ADDRESS THE ISSUES NOTED ABOVE.
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SEC COMMENT 2
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Schedule  of  Investments,  All  Funds -- The  value  of  certain  fixed  income
securities  is  substantially  lower  than the face  amount of such  securities.
Confirm that SEI is appropriately  footnoting any securities that are in default
or are non-income producing or that are being fair valued. Additionally, are any
such securities sub-prime in nature?

SEI RESPONSE TO COMMENT 2
SEI CONFIRMS THAT SECURITIES THAT ARE IN DEFAULT,  NON-INCOME PRODUCING OR BEING
FAIR VALUED ARE  APPROPRIATELY  BEING TICKMARKED ON THE SCHEDULE OF INVESTMENTS.
TO THE EXTENT ANY OF THE INVESTMENTS  WERE SUB-PRIME IN NATURE,  IF THEY HAD


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ANY OF THE CHARACTERISTICS (SUCH AS IN DEFAULT,  NON-INCOME  PRODUCING,  OR FAIR
VALUED), THEY WOULD BE APPROPRIATELY  TICKMARKED ON THE SCHEDULE OF INVESTMENTS.
HOWEVER, SEI DOES NOT BELIEVE THAT BECAUSE SECURITIES MAY HAVE BEEN SUB-PRIME IN
NATURE WOULD  NECESSITATE  A SEPARATE  TICKMARK  UNLESS THEY MET THE  CONDITIONS
DESCRIBED ABOVE.
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SEC COMMENT 3
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Certain of the fixed  income  funds,  Long  Duration  Fund  (SIIT) and  Extended
Duration  Fund (SIIT),  state in their  prospectus  that they invest "in a broad
array of high quality  fixed income  instruments."  As of the date of the annual
report,  Long  Duration and Extended  Duration had 60% of their  investments  in
non-agency mortgage backed securities.  Please explain how and if these types of
investments met the Funds' quality standards.

SEI RESPONSE TO COMMENT 3
THE FUNDS' INVESTMENT IN NON-AGENCY MORTGAGE BACKED SECURITIES WAS IN COMPLIANCE
WITH THEIR INVESTMENT STRATEGIES.  THE FUNDS' PROSPECTUS STATES THAT THEY INVEST
"IN A BROAD ARRAY OF HIGH  QUALITY  FIXED  INCOME  INSTRUMENTS,  INCLUDING . . .
MORTGAGE-BACKED  SECURITIES AND  COLLATERALIZED  MORTGAGE-BACKED  SECURITIES" IT
FURTHER STATES THAT THE "FUND WILL INVEST  PRIMARILY IN FIXED INCOME  SECURITIES
RATED IN ONE OF THE THREE HIGHEST  RATING  CATEGORIES BY A MAJOR RATING  AGENCY,
OR, IF UNRATED,  DETERMINED BY THE SUB- ADVISER TO BE OF EQUIVALENT QUALITY AND,
TO A MORE LIMITED EXTENT, IN FIXED INCOME SECURITIES RATED IN THE FOURTH HIGHEST
RATING  CATEGORY . . ." AS OF THE DATE OF THE ANNUAL  REPORT,  THE LONG DURATION
FUND'S NON-AGENCY MORTGAGE BACKED SECURITY HOLDINGS WERE RATED 98% AAA AND 2% AA
BY S&P AND THE EXTENDED  DURATION  FUND'S  NON-AGENCY  MORTGAGE  BACKED SECURITY
HOLDINGS WERE RATED 100% AAA BY S&P.
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SEC COMMENT 4
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Schedule  of  Investments,   All  funds --  Many  funds  utilize  a  "non-agency
mortgage-backed  securities"  category  as  well  as an  "other  mortgage-backed
securities" category. Please explain the difference between these categories and
whether they should be combined.

SEI RESPONSE TO COMMENT 4
SEI  BELIEVES  THAT  EACH OF  THESE  CATEGORIES  REPRESENT  DIFFERENT  TYPES  OF
SECURITIES  AND SHOULD BE  DISCLOSED IN SEPARATE  CATEGORIES  ON THE SCHEDULE OF
INVESTMENTS.  UNDER  "MORTGAGE  BACKED"  SECURITIES  SEI HAS BOTH A  "NON-AGENCY
MORTGAGED BACKED" AND AN "AGENCY BACKED" CATEGORY.  THE "NON-AGENCY"  SECURITIES
ARE ISSUED BY COMPANIES OTHER THAN AGENCIES (FNMA,  FHLMC AND GNMA). THE "AGENCY
BACKED"  SECURITIES ARE ISSUED BY AGENCIES.  UNDER THE "ASSET BACKED"  GROUPING,
SEI HAS A  "MORTGAGE  RELATED"  AND AN  "OTHER  ASSET  BACKED"  CATEGORIES.  THE
"MORTGAGE RELATED" CATEGORY INCLUDES HOME EQUITY LOANS. THE "OTHER ASSET BACKED"
CATEGORY INCLUDES CLO'S AND CDO'S.
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SEC COMMENT 5
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Schedule  of  Investments  & Notes to  Financials,  All Funds -- Were any of the
Funds  heavily  invested in sub-prime  securities?  If so, were there any issues
with respect to the Funds' valuation?

SEI RESPONSE TO COMMENT 5
"SUB-PRIME" IS GENERALLY  CONSIDERED TO BE NON-AGENCY  MORTGAGE  SECURITIES THAT
HOLD SUB-PRIME COLLATERAL (TYPICALLY MORTGAGES BELOW A FICO SCORE OF 620). AS OF
THE DATE OF THE MOST RECENT  ANNUAL  REPORTS FOR ALL FUNDS,  THE ONLY FUNDS THAT
HAD  SUB-PRIME  EXPOSURE  GREATER  THAN 5% WERE:  SIIT  EXTENDED  DURATION  FUND
(27.9%);  SIIT LONG DURATION FUND (28.8%); AND SIIT ENHANCED LIBOR OPPORTUNITIES
FUND (11.2%).

REGARDING  WHETHER  THERE WERE ANY ISSUES WITH RESPECT TO THE FUNDS'  VALUATION,
ALTHOUGH HIGH  VOLATILITY,  REDUCED  LIQUIDITY AND WIDE BID/ASK  SPREADS IN MOST
FIXED INCOME  SECTORS HAVE BEEN A CHALLENGE,  WE HAVE CONTINUED TO RELY UPON THE
FUNDS'  BOARD-APPROVED  PRICING  PROCEDURES,  WHICH WE THINK HAVE  CONTINUED  TO
OPERATE EFFECTIVELY IN THIS MARKET ENVIRONMENT.

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SEC COMMENT 6
-------------
Schedule of Investments,  All Funds -- SEI should  consider  disclosing the rate
for all preferred securities held as of period end.

SEI RESPONSE TO COMMENT 6
SEI  AGREES,  AND IN THE  FUTURE  WILL  DISCLOSE  THE  RATE  FOR  ALL  PREFERRED
SECURITIES,  TO THE EXTENT  THAT SUCH RATES ARE  AVAILABLE,  IN THE  SCHEDULE OF
INVESTMENTS.
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SEC COMMENT 7
-------------
Schedule of  Investments  and Statement of Assets and  Liabilities  -- For funds
that participate in securities lending and purchase the SEI Liquidity Fund, L.P.
with cash  collateral  received from  securities  lending,  why does the payable
balance related to securities  lending collateral on the Statement of Assets and
Liabilities  differ  from the  market  value  of the SEI  Liquidity  Fund,  L.P.
reported on the Schedule of Investments?


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SEI RESPONSE TO COMMENT 7
THE VALUE SHOWN ON THE SCHEDULE OF  INVESTMENTS  IS THE VALUE OF THE  INVESTMENT
RELATED TO CASH COLLATERAL RECEIVED FOR SECURITIES ON LOAN AS OF THE DATE OF THE
FINANCIALS.  THE  PAYABLE  BALANCE ON THE  STATEMENT  OF ASSETS AND  LIABILITIES
REPRESENTS THE TOTAL AMOUNT OF THE CASH COLLATERAL  RECEIVED AND INVESTED IN THE
SEI LIQUIDITY  FUND,  L.P. THE DIFFERENCE IS THE LOSS IN VALUE THAT HAS OCCURRED
IN THE SEI LIQUIDITY  FUND. IF THE LIQUIDITY  FUND HAD  MAINTAINED A $1.00 VALUE
THEN THE AMOUNTS  SHOWN ON THE  SCHEDULE OF  INVESTMENTS  AND THE  STATEMENT  OF
ASSETS AND LIABILITIES WOULD HAVE BEEN THE SAME.
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SEC COMMENT 8
-------------
Schedule  of  Investments,  All  Funds -- For  Funds  that invest  in  tri-party
repurchase  agreements,  consider  disclosing  the third party to the repurchase
agreement.

SEI RESPONSE TO COMMENT 8
SEI AGREES THAT REGULATION S-X 12-12 INDICATES THAT ALL PARTIES TO THE TRI-PARTY
REPURCHASE AGREEMENTS SHOULD BE DISCLOSED IN THE FUND'S FINANCIAL STATEMENTS. IT
IS OUR BELIEF THAT THIS DISCLOSURE REQUIREMENT IS NOT WIDELY FOLLOWED ACROSS THE
INDUSTRY.  GENERALLY,  ONLY THE FUND AND  COUNTERPARTY  ARE  DISCLOSED,  AND THE
CUSTODIAN IS GENERALLY  NOT  DISCLOSED.  IT IS OUR FEELING THAT THE CUSTODIAN IS
GENERALLY  NOT  DISCLOSED  BECAUSE  IT WOULD  NOT BE USEFUL  INFORMATION  TO THE
SHAREHOLDER.  WE  RESPECTFULLY  REQUEST  THAT YOU GIVE  THIS  MATTER  ADDITIONAL
CONSIDERATION  AND INFORM US IF YOU STILL BELIEVE THAT IT IS IMPERATIVE  THAT WE
ADD THE ADDITIONAL DISCLOSURE IN THE FUTURE.
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SEC COMMENT  9
--------------
Schedule of Investments  and Statement of Assets and  Liabilities,  All Funds --
For funds that  invest in swap  contracts,  please  explain  how the  unrealized
appreciation  and depreciation are being reported on the Statement of Assets and
Liabilities.  It does not appear that gross  unrealized  appreciation  and gross
unrealized  depreciation are being reported; are their master netting agreements
in place?

SEI RESPONSE TO COMMENT 9
THE  DIFFERENCE  BETWEEN THE VALUES OF THE SWAPS ON THE SCHEDULE OF  INVESTMENTS
AND  STATEMENT  OF  ASSETS  AND  LIABILITIES  IS DUE TO THE COST  VALUE  THAT IS
APPLICABLE TO SOME OF THE SWAPS.  THE VALUE SHOWN ON THE SCHEDULE OF INVESTMENTS
IS THE  UNREALIZED  APPRECIATION  OR  DEPRECIATION.  THE STATEMENT OF ASSETS AND
LIABILITIES  SHOWS THE MARKET  VALUE FOR THE SWAP  POSITIONS AS WELL AS ANY COST
ASSOCIATED WITH THE SWAPS.
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SEC COMMENT 10
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Notes to Financial  Statements, All Funds -- Are acquired fund fees and expenses
excluded from the Funds' expense  limitation  agreements?  If so, this should be
disclosed.

SEI RESPONSE TO COMMENT 10
ACQUIRED FUND FEES AND EXPENSES ARE EXCLUDED FROM THE FUNDS' EXPENSE  LIMITATION
AGREEMENTS.  GOING FORWARD,  SEI WILL DISCLOSE THIS FACT IN THE FUNDS' FINANCIAL
STATEMENTS.

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SEC COMMENT 11
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Form N-PX Filing, All Funds -- Form N-PX for the Funds was filed on September 2,
2008.  Per the Form,  the filing must be  completed  not later than August 31 of
each year. In the future,  SEI should ensure that Form N-PX is filed in a timely
manner.

SEI RESPONSE TO COMMENT 11
SEI STRONGLY  BELIEVES THAT THE FILING OF FORM N-PX FOR THE FUNDS WAS TIMELY, AS
AUGUST 31, 2008 WAS A SUNDAY AND SEPTEMBER 1, 2008 WAS A HOLIDAY. IN FILING FORM
N-PX FOR THE FUNDS, SEI RELIED ON THE FOLLOWING:  (1) RULE 0-2(a) UNDER THE 1940
ACT WHICH  STATES  THAT "[I]F THE LAST DAY FOR THE TIMELY  FILING OF SUCH PAPERS
FALLS ON A SATURDAY,  SUNDAY, OR HOLIDAY,  SUCH PAPERS MAY BE FILED ON THE FIRST
BUSINESS DAY  FOLLOWING," (2)  CONFIRMATION  OF FILING  DEADLINE  WITH THE EDGAR
HELPLINE FOR FORM N-PX PRIOR TO FILING ON SEPTEMBER 2, 2008, AND (3) INDEPENDENT
CONFIRMATION OF THE FILING DEADLINE BY OUR PRINTING VENDORS.
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SEC COMMENT 12
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MDFP, Ultra  Short Bond Fund (SDIT) -- The  prospectus  for the Ultra Short Bond
Fund states that the Fund has a higher  degree of risk of principal  volatility,
whereas  the MDFP states that the Fund has  minimal  principal  volatility.  SEI
should clarify the Fund's risk of principal  volatility and conform the language
in both the MDFP and prospectus.

SEI RESPONSE TO COMMENT 12
SEI WILL CONFORM THE MDFP LANGUAGE TO THE  PROSPECTUS.  PLEASE NOTE THAT,  WHILE
THE  LANGUAGE  WAS   INCONSISTENT,   THIS  REFLECTS   DIFFERENCES   IN  SENTENCE
CONSTRUCTION  RATHER THAN DIFFERENCES IN MEANING.  IN OTHER WORDS, WHILE WRITTEN
INCONSISTENTLY, BOTH DISCLOSURES WERE ACCURATE. MORE SPECIFICALLY, THE REFERENCE
TO  PRINCIPAL  VOLATILITY  IN THE  PROSPECTUS  WAS  STATED ON A  RELATIVE  BASIS
COMPARED  TO MONEY  MARKET  FUNDS,  IN THAT THE ULTRA SHORT BOND FUND WOULD HAVE
"HIGHER  PRINCIPAL  VOLATILITY"  THAN A MONEY MARKET FUND,  WHICH IS AN ACCURATE
STATEMENT.  IN THE MDFP,  THE  REFERENCE  TO  PRINCIPAL  VOLATILITY  WAS  STATED
OBJECTIVELY  RATHER THAN ON A RELATIVE BASIS COMPARED TO MONEY MARKET FUNDS.  ON
AN OBJECTIVE  BASIS,  IT WAS STATING THAT THE FUND IS EXPECTED TO HAVE  "MINIMAL
PRINCIPAL  VOLATILITY," WHICH AGAIN IS AN ACCURATE STATEMENT.  THEREFORE,  WHILE
THE FUND WOULD HAVE "HIGHER"  PRINCIPAL  VOLATILITY THAN A MONEY MARKET FUND, IT
IS STILL  EXPECTED  TO HAVE  "MINIMAL"  PRINCIPAL  VOLATILITY.  EVEN THOUGH BOTH
STATEMENTS  WERE  ACCURATE,   WE  DO  AGREE  THAT  THE  DIFFERENCE  IN  SENTENCE
CONSTRUCTION MAY BE CONFUSING.
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SEC COMMENT 13
--------------
Schedule  of  Investments, International  Fixed  Income Fund (SIT) -- Footnote H
states that the swap value of Lehman Brothers Global  Aggregate EX USD RBI Ser 1
has been  reduced  by $772  (000) to reflect  the  collectability  of the value.
Please explain.

SEI RESPONSE TO COMMENT 13
AFTER LEHMAN  BROTHERS FILED FOR  BANKRUPTCY,  SEI FAIR VALUED THE SWAP BASED ON
THE  COLLECTABILITY  OF THE NET  RECEIVABLE  VALUE.  THE  FAIR  VALUE  COMMITTEE
DETERMINED THAT THE VALUE OF THE RECEIVABLE SHOULD BE REDUCED TO APPROXIMATE THE
VALUE OF SENIOR UNSECURED DEBT.
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SEC COMMENT 14
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Prospectus for Emerging Markets Debt Fund (SIT, SIIT) and Core Fixed Income Fund
(SIMT  and  SIIT) --  The  Funds  invest  heavily  in a  variety  of  derivative
instruments,  however,  the  prospectus  does not mention the risk of derivative
investments  with respect to the Emerging  Markets Debt Fund and the  prospectus
does not  discuss  all types of  derivatives  that the Core  Fixed  Income  Fund
invests in. For Funds investing heavily in derivative instruments,  there should
be adequate disclosure in the Funds' prospectus.

SEI RESPONSE TO COMMENT 14
DERIVATIVE  INSTRUMENTS  ARE  NOT  PART  OF THE  EMERGING  MARKETS  DEBT  FUND'S
PRINCIPAL INVESTMENT STRATEGY. THEREFORE, SUCH INSTRUMENTS ARE NOT REFERENCED IN
THE INVESTMENT STRATEGY AND RISK SECTION OF THE FUND'S PROSPECTUS. MOREOVER, SEI
RESPECTFULLY  DISAGREES THAT THE EMERGING  MARKETS DEBT FUND INVESTS  HEAVILY IN
DERIVATIVE  INSTRUMENTS AS SUCH  INSTRUMENTS  CONSTITUTED NO MORE THAN 1% OF THE
FUNDS' NET ASSETS AS OF THE DATE OF THE ANNUAL REPORTS.

WITH  RESPECT TO THE CORE FIXED INCOME FUND,  SEI BELIEVES  THAT THE  PROSPECTUS
ADEQUATELY  DESCRIBES THE TYPES OF DERIVATE  INSTRUMENTS  PURCHASED BY THE FUND.
THE FUND'S PRINCIPAL  INVESTMENT  STRATEGY STATES THAT THE FUND "MAY ALSO ENGAGE
IN CURRENCY  TRANSACTIONS USING FUTURES,  FOREIGN CURRENCY FORWARD CONTRACTS AND
OTHER DERIVATIVES . . ." THE PROSPECTUS ALSO HAS RISK DISCLOSURE WITH RESPECT TO
SUCH DERIVATIVES AS FUTURES CONTRACTS, OPTIONS, FORWARD CONTRACTS AND SWAPS.
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SEC COMMENT 15
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Schedule of  Investments,  Money  Market Fund (SDIT) and Prime  Obligation  Fund
(SDIT) -- Both the  Money  Market  Fund and Prime  Obligation  Fund have a large
percentage  invested in illiquid  securities,  11.56% and 15.49%,  respectively.
Please  explain  why  these  Funds  exceeded  the  10%  limitation  on  illiquid
securities  and confirm that the Board is aware that the Funds have exceeded the
10% limitation.

SEI RESPONSE TO COMMENT 15
SINCE LATE 2007 THE FUNDS AT ISSUE (I.E.,  SDIT MONEY MARKET FUND AND SDIT PRIME
OBLIGATION FUND) HAVE  EXPERIENCED  PERIODS OF ILLIQUID  SECURITIES  HOLDINGS IN
EXCESS OF 10%. THESE EVENTS WERE CAUSED BY SECURITIES (E.G.,  SIVS) WHICH


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BECAME ILLIQUID AFTER ACQUISITION BY THE FUNDS. WHEN CERTAIN SECURITIES IN THESE
FUNDS WENT INTO DEFAULT,  THEY WERE  ULTIMATELY  PLACED INTO THE FUNDS' ILLIQUID
`BUCKETS',  THEREBY CAUSING THE PERCENTAGE OF ILLIQUID  SECURITIES TO RISE ABOVE
THE 10%  LIMIT.  THE  FUNDS'  BOARD  WAS  AWARE OF THE  STATUS  OF THE  ILLIQUID
SECURITIES  IN THESE FUNDS AND MADE  DETERMINATIONS  THAT IT WAS NOT IN THE BEST
INTEREST OF THE FUNDS TO ATTEMPT TO SELL THE ILLIQUID  POSITIONS INTO DISTRESSED
MARKETS.  CURRENTLY, THE ILLIQUID SECURITIES HOLDINGS OF BOTH FUNDS AT ISSUE ARE
AGAIN BELOW 10% (SPECIFICALLY, AS OF MARCH 31, 2009, THE PERCENTAGES OF ILLIQUID
SECURITIES  IN SDIT MONEY MARKET FUND AND SDIT PRIME  OBLIGATION  FUND ARE 0.00%
AND 1.46%, RESPECTIVELY).
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SEC COMMENT 16
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Weighted Average Maturity, Short Duration Government Fund (SDIT) and Ultra Short
Fund (SDIT) -- Please confirm that the weighted average maturity for  the  Funds
is less than 3 years as stated in the prospectus.

SEI RESPONSE TO COMMENT 16
SEI CONFIRMS THAT AS OF JANUARY 31, 2008, THE WEIGHTED  AVERAGE MATURITY FOR THE
SDIT SHORT DURATION AND SDIT ULTRA SHORT BOND FUNDS WAS 1.2 YEARS AND 1.8 YEARS,
RESPECTIVELY.  IN THE FINANCIAL  STATEMENTS SEI SHOWS THE MATURITY DATE FOR EACH
POSITION,  WHILE THE WEIGHTED AVERAGE MATURITY  CALCULATION IS BASED ON THE NEXT
RESET DATE FOR EACH SECURITY.
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SEC COMMENT 17
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Schedule  of  Investments, Large Cap  Disciplined  Equity Fund (SIIT) -- Per the
Fund's prospectus,  the Fund will invest under normal circumstances at least 80%
of its net  assets  in  equity  securities  of large  companies.  Is the  Fund's
investment in the SEI LIBOR Plus Portfolio,  L.P.  considered to be part of this
80% policy? Please clarify.

SEI RESPONSE TO COMMENT 17
THE FUND'S  INVESTMENT  IN THE SEI LIBOR PLUS  PORTFOLIO  ("LIBOR  PLUS") IS ONE
COMPONENT OF AN "ALPHA TRANSPORT"  STRATEGY WHICH PROVIDES INVESTORS WITH EQUITY
MARKET EXPOSURE  THROUGH THE USE OF EQUITY  DERIVATIVES,  WITH THE POTENTIAL FOR
ADDITIONAL RETURNS FROM AN UNDERLYING INVESTMENT IN LIBOR PLUS. SINCE IT IS PART
OF AN EQUITY-BASED "ALPHA TRANSPORT" STRATEGY,  THE FUND'S INVESTMENT IN THE SEI
LIBOR PLUS  PORTFOLIO  ("LIBOR  PLUS"),  WHEN  PAIRED  WITH THE  RELATED  EQUITY
DERIVATIVES,  IS CONSIDERED  TO BE PART OF THE FUND'S 80% POLICY.  THE FOLLOWING
DISCLOSURE FROM THE PROSPECTUS SPECIFIES THAT SUCH A STRATEGY IS CONSIDERED PART
OF THE FUND'S PRINCIPAL INVESTMENT STRATEGY:

"CERTAIN  SUB-ADVISERS  USE PORTFOLIO  STRATEGIES THAT ARE DESIGNED TO CORRELATE
WITH A  PORTFOLIO  OF LARGE CAP EQUITY  SECURITIES,  BUT WHICH ARE  COMPOSED  OF
DERIVATIVE  INSTRUMENTS  BACKED BY OTHER TYPES OF  SECURITIES.  THESE  PORTFOLIO
STRATEGIES ARE INCLUDED IN THE FUND'S PRINCIPAL  INVESTMENT  STRATEGY  DESCRIBED
ABOVE. THE SUB-ADVISERS PURCHASE DERIVATIVES, GENERALLY USING ONLY A FRACTION OF
THE ASSETS THAT WOULD BE NEEDED TO PURCHASE THE EQUITY SECURITIES  DIRECTLY,  SO
THAT THE  REMAINDER OF THE ASSETS IN A PORTFOLIO  MAY BE INVESTED IN OTHER TYPES
OF  SECURITIES.  THEREFORE,  A SUB-ADVISER  WOULD SEEK TO OUTPERFORM A LARGE CAP
BENCHMARK BY PURCHASING  DERIVATIVES  CORRELATED TO A BROAD LARGE CAP INDEX, AND
INVESTING  THE  REMAINING  ASSETS IN OTHER  TYPES OF  SECURITIES  TO ADD  EXCESS
RETURN.  THIS  PORTION OF THE FUND'S  ASSETS MAY BE  INVESTED IN A WIDE RANGE OF
ASSET CLASSES OTHER THAN LARGE CAP EQUITIES,  INCLUDING  ETFS,  DERIVATIVES  AND
CASH  EQUIVALENTS.  PURSUANT TO A DERIVATIVES  STRATEGY,  THE FUND MAY INVEST IN
U.S. AND FOREIGN MARKETS,  INCLUDING EMERGING MARKETS,  CORPORATE AND GOVERNMENT
FIXED  INCOME   SECURITIES  OF  DIFFERENT   TYPES  AND   MATURITIES,   INCLUDING
MORTGAGE-BACKED  OR OTHER  ASSET-BACKED  SECURITIES,  SECURITIES RATED BELOW THE
FOURTH  HIGHEST  RATING  CATEGORY BY AN NRSRO (JUNK  BONDS),  AND  REPURCHASE OR
REVERSE  REPURCHASE  AGREEMENTS."

PLEASE SEE SEI RESPONSE TO COMMENT 18 (BELOW) FOR MORE DETAILS  REGARDING  LIBOR
PLUS.
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SEC COMMENT 18
--------------
Schedule of  Investments,  Enhanced LIBOR Opportunities  Fund -- Does the Fund's
investment in the SEI LIBOR Plus Portfolio, L.P., representing 32% of the Fund's
net assets at period end, meet the prospectus requirements? Please clarify.

SEI RESPONSE TO COMMENT 18
THE FUND'S  INVESTMENT IN LIBOR PLUS MEETS THE  PROSPECTUS  REQUIREMENTS.  LIBOR
PLUS IS A PORTFOLIO WITHIN SEI ALPHA STRATEGY PORTFOLIOS,  LP ("SASP"). SASP WAS
ESTABLISHED  PRIMARILY AS AN  INVESTMENT  MEDIUM TO ALLOW SERIES OF SIIT TO MORE
EFFICIENTLY  PURSUE THEIR  RESPECTIVE  INVESTMENT  STRATEGIES.  THE FUND'S BOARD
APPROVED THIS INVESTMENT OPTION IN JUNE 2007.

THE FUND'S  PROSPECTUS  (UNDER THE SECTION TITLED 'MORE  INFORMATION  ABOUT FUND
INVESTMENTS') STATES "[T]O ACHIEVE ITS INVESTMENT  GOAL, EACH FUND MAY INVEST IN
ONE OR MORE PORTFOLIOS  (EACH, A "PORTFOLIO") OF SEI ALPHA STRATEGY  PORTFOLIOS,
LP, A REGISTERED OPEN-END INVESTMENT COMPANY WHICH WAS ESTABLISHED TO PERMIT THE
FUNDS  (AND  OTHER  SIMC  SPONSORED  MUTUAL  FUNDS) TO PURSUE  THEIR  RESPECTIVE
INVESTMENT  STRATEGIES IN AN EFFICIENT  MANNER. A FUND MAY INVEST IN A PORTFOLIO
ONLY IF THE PORTFOLIO  INVESTS IN SECURITIES AND PURSUES  INVESTMENT  STRATEGIES
THAT ARE CONSISTENT WITH THE FUND'S INVESTMENT STRATEGY."

THE FUND'S  INVESTMENT  IN LIBOR PLUS,  AS  DISCLOSED  IN THE  PROSPECTUS,  IS A
COMPONENT OF THE FUND'S OVERALL INVESTMENT STRATEGY.
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SEC COMMENT 19
--------------

Statement of Assets and  Liabilities, Prime Obligation Fund (SLAT) -- SEI should
consider disclosing the number of authorized shares for the Fund.


                                       5





SEI RESPONSE TO COMMENT 19
SEI AGREES,  AND WE WILL  DISCLOSE  THE  AUTHORIZED  SHARES IN THE  STATEMENT OF
ASSETS AND LIABILITIES BEGINNING WITH THE ANNUAL REPORT DATED JUNE 30, 2009.
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SEC COMMENT 20
--------------
Treasury  Guarantee  Program,  Prime  Obligation  Fund (SLAT and SDIT) -- Is the
waiver of  investment  advisory  and/or  administration  fees  exclusive  of the
expenses related to the Treasury Guarantee Program?

SEI RESPONSE TO COMMENT 20
THE EXPENSES  ASSOCIATED WITH THE TREASURY GUARANTEE PROGRAM ARE NOT INCLUDED IN
THE EXPENSE CAPS FOR THE SDIT OR SLAT PRIME OBLIGATION FUNDS.
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SEC COMMENT 21
--------------
Statement of  Operations  and  Notes  to  Financial  Statements,  STET -- Is the
shareholder  servicing fee the same as the  Administrative  Servicing  Fee? Both
fees are disclosed in the notes, but only the Shareholder Servicing Fee is being
disclosed in the Statement of Operations.

SEI RESPONSE TO COMMENT 21
BOTH  THE  SHAREHOLDER  SERVICING  FEE  AND  ADMINISTRATIVE  SERVICING  FEE  ARE
COMBINED,  BY  CLASS,  IN THE  SHAREHOLDER  SERVICING  FEE ON THE  STATEMENT  OF
OPERATIONS.  THERE IS A FOOTNOTE TO THIS FEE THAT  DESCRIBES  WHAT IS  INCLUDED.
BEGINNING  WITH THE FEBRUARY 28, 2009  SEMI-ANNUAL  REPORT,  SEI WILL CHANGE THE
CAPTION  ON THE  STATEMENT  OF  OPERATIONS  TO  ADMINISTRATIVE  AND  SHAREHOLDER
SERVICING FEE -- CLASS B AND ADMINISTRATIVE  AND  SHAREHOLDER  SERVICING  FEE --
CLASS C. THE ADMINISTRATIVE SERVICING FEE IS NOT APPLICABLE TO CLASS A SHARES.
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SEC COMMENT 22
--------------
Notes to Financial Statements,  STET -- Consider  disclosing ROC-SOP adjustments
recorded as of the fiscal year end in the Notes to Financials.

SEI RESPONSE TO COMMENT 22
SEI  AGREES  THAT  ROC-SOP  ADJUSTMENTS  SHOULD  BE  DISCLOSED  IN THE  NOTES TO
FINANCIALS.  FOR THE YEAR ENDED AUGUST 31,  2008,  NO ROC-SOP  ADJUSTMENTS  WERE
REQUIRED TO BE RECORDED.  BEGINNING WITH THE AUGUST 31, 2009 ANNUAL REPORT,  SEI
WILL INCLUDE A NOTE STATING THAT THERE WERE NO PERMANENT  DIFFERENCES  AS OF THE
YEAR END, OR WILL  DISCLOSE  ANY  ROC-SOP  ADJUSTMENTS  THAT ARE  REQUIRED TO BE
RECORDED.
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SEC COMMENT 23
--------------
Securities Lending Collateral,  Investment in SEI Liquidity  Portfolio,  L.P. --
For the Funds investing cash collateral from securities lending in SEI Liquidity
Portfolio,  L.P., are the unrealized  losses in this investment  included in the
Net Asset Value Per Share of the Funds holding the collateral?

SEI RESPONSE TO COMMENT 23
YES,  THE NET ASSET VALUE PER SHARE FOR EACH OF THE SEI FUNDS  INVESTING  IN THE
SEI LIQUIDITY FUND HAS BEEN REDUCED BY THE UNREALIZED LOSSES FROM THE INVESTMENT
IN THE SEI LIQUIDITY FUND.
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SEC COMMENT 24
--------------
Securities Lending Collateral,  Investment in SEI Liquidity  Portfolio,  L.P. --
Since there is currently a loss  associated  with the Funds'  investment of cash
collateral from securities lending in the SEI Liquidity Portfolio,  L.P., why is
disclosure  relative  to these  losses  not  present  in the Notes to  Financial
Statements?

SEI RESPONSE TO COMMENT 24
SEI  CURRENTLY  DISCUSSES  THE USE OF THE SEI  LIQUIDITY  FUND AS AN  INVESTMENT
VEHICLE IN THE AGREEMENTS  AND  OTHER TRANSACTIONS WITH AFFILIATES -- INVESTMENT
IN AFFILIATED SECURITY AND  SECURITIES LENDING NOTES IN THE NOTES TO FINANCIALS.
SEI ALSO  DISCLOSES  IN THE  SECURITIES  LENDING  NOTE  THAT THE  INVESTMENT  IS
NOT GUARANTEED  AND  CAN  LOSE  VALUE.  SEI  IS  NOT AWARE OF A  REQUIREMENT  TO
INCLUDE SPECIFIC DISCLOSURE REGARDING THESE LOSSES IN THE NOTES TO FINANCIALS.
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                                       6





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SEC COMMENT 25
--------------
Securities Lending Collateral,  Investment in SEI Liquidity  Portfolio,  L.P. --
Where are the realized and unrealized  losses  associated  with this  investment
being included in the Statement of Operations?

SEI RESPONSE TO COMMENT 25
THE REALIZED AND UNREALIZED  LOSSES  ASSOCIATED  WITH THE SEI LIQUIDITY FUND ARE
INCLUDED  IN THE LINE  FOR  AFFILIATED  INVESTMENTS  IN THE  "NET  REALIZED  AND
UNREALIZED   GAIN  (LOSS)  ON   INVESTMENTS"   AND  "NET  CHANGE  IN  UNREALIZED
APPRECIATION  (DEPRECIATION)  ON  INVESTMENTS"  SECTIONS  ON  THE  STATEMENT  OF
OPERATIONS FOR EACH FUND.
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SEC COMMENT 26
--------------
Underlying  Funds, SAAT -- What is  SEI's  policy  in  terms  of  including  the
financial  statements  of the  underlying  funds  and what  percentage  is SEI's
threshold for including such financial statements?  As an example, several funds
have a greater than 50%  investment  in Core Fixed Income Fund (SIMT),  however,
the  financial  statements  for Core Fixed  Income Fund are not  included in the
financials of SAAT.

SEI RESPONSE TO COMMENT 26
SEI BELIEVES THAT FOR ANY UNDERLYING FUND THAT IS EQUAL TO OR EXCEEDS 75% OF THE
FUND'S  INVESTMENTS,  THE  FINANCIAL  STATEMENTS  SHOULD  BE  INCLUDED.  FOR ANY
INVESTMENT  OVER 50%,  LANGUAGE  IS INCLUDED  TO EXPLAIN  THE  OBJECTIVE  OF THE
UNDERLYING  FUND AND  INFORMS A  SHAREHOLDER  WHERE THEY CAN  LOCATE  ADDITIONAL
INFORMATION ON THE UNDERLYING  FUND  (INCLUDING  PROSPECTUS,  SAI, AND FINANCIAL
STATEMENTS).
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SEC COMMENT 27
--------------
Financial Highlights and Notes to Financial Statements, Defensive Strategy Fund,
Class I (SAAT)  and  Core  Market  Strategy  Fund,  Class I (SAAT) --  A note is
included in the financial  highlights  stating that the ratio of net expenses to
average net assets excludes the Administrative  Servicing Fee which currently is
not being charged to the Class due to the immaterial  amount.  This same note is
also present in the Notes to Financial Statements. Please explain.

SEI RESPONSE TO COMMENT 27
CURRENTLY  ONLY SEED MONEY IS  INVESTED  IN THE CLASS I SHARES FOR BOTH THE SAAT
DEFENSIVE STRATEGY AND SAAT CORE MARKET STRATEGY FUNDS. DUE TO THE SMALL SIZE OF
THE NET  ASSETS,  THE DAILY  ADMINISTRATIVE  SERVICING  FEE AMOUNTS TO LESS THAN
$0.01  PER DAY SO SEI IS NOT  CHARGING  THE FEE.  ONCE  ADDITIONAL  SHAREHOLDERS
INVEST IN THE CLASS, SEI WILL BEGIN TO CHARGE THE FEES.
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SEC COMMENT 28
--------------
Structure of SAAT -- Are there any limits  placed on overall expenses  since the
SAAT Funds are charging  various fees such as distribution  fees, and these same
fees may also be  charged  by the  underlying  fund.  How does SEI  ensure  that
excessive fees are not being charged?

SEI RESPONSE TO COMMENT 28
SEI  ENSURES  THAT  EXCESSIVE  FEES ARE NOT BEING  CHARGED  TO  SHAREHOLDERS  BY
SUBMITTING  SUCH FEES TO THE BOARD OF  TRUSTEES  OF THE  FUNDS  FOR  REVIEW  AND
APPROVAL. FURTHERMORE,  OVERALL FEES ARE SUBJECT TO LIMITS, DUE TO VOLUNTARY FEE
WAIVERS BY THE ADMINISTRATOR,  ADVISER AND/OR DISTRIBUTOR AT THE SAAT FUND LEVEL
AND  IN  MOST  INSTANCES  AT  THE  UNDERLYING  FUND  LEVEL.  FOR  INSTANCE,  SEI
INVESTMENTS  GLOBAL  FUNDS  SERVICES,  THE  ADMINISTRATOR  TO  THE  SAAT  FUNDS,
CURRENTLY VOLUNTARILY WAIVES A PORTION OF ITS FEES IN ORDER TO KEEP TOTAL DIRECT
OPERATING EXPENSES OF THE SAAT FUNDS AT A SPECIFIED LEVEL.

FINALLY,  SEI HAS ENSURED THAT THE SAAT FUNDS AND UNDERLYING FUNDS DO NOT CHARGE
EXCESSIVE  DISTRIBUTION  (12B-1) OR SHAREHOLDER  SERVICING FEES. WITH RESPECT TO
THESE FEES,  WE ASSUME THE STAFF IS  REFERRING TO THE  LIMITATIONS  OF NASD RULE
2830.  ONLY CLASS D SHARES OF THE SAAT FUNDS CHARGE A DISTRIBUTION  (12B-1) FEE.
SINCE THE CLASS A SHARES OF THE UNDERLYING  FUNDS (WHICH IS THE SHARE CLASS USED
BY THE SAAT FUNDS) DO NOT CHARGE A DISTRIBUTION FEE, SEI ONLY HAS TO ENSURE THAT
THE  DISTRIBUTION  FEES FOR CLASS D SHARES AT THE SAAT LEVEL ARE NOT  EXCESSIVE.
CLASS D SHARES OF THE SAAT  FUNDS ARE ALSO  SUBJECT TO A  SHAREHOLDER  SERVICING
PLAN THAT  PERMITS EACH FUND TO PAY THE  DISTRIBUTOR  A FEE IN  CONNECTION  WITH
ONGOING SERVICING OF SHAREHOLDER ACCOUNTS AT THE ANNUAL RATE OF 0.25%.  ALTHOUGH
CLASS A SHARES  OF THE  UNDERLYING  FUNDS  ARE  ALSO  SUBJECT  TO A  SHAREHOLDER
SERVICING PLAN, SUCH PLAN ONLY PERMITS FEES FOR ADMINISTRATIVE SERVICES THAT ARE


                                       7




OF A TYPE  THAT  IS NOT  SUBJECT  TO  NASD  RULE  2830,  AND  THEREFORE  ARE NOT
AGGREGATED WITH THE SAAT LEVEL FEES FOR PURPOSES OF DETERMINING  CONFORMITY WITH
THAT RULE.

PLEASE  CONTACT  STEPHEN  PANNER AT (610)  676-1189 IF YOU HAVE ANY QUESTIONS OR
COMMENTS.

Very truly yours,

/s/ Stephen F. Panner
---------------------
Stephen F. Panner

Controller and Chief Financial Officer

cc:  Robert A. Nesher
     Russell Emery
     Timothy D. Barto
     John J. McCue
     James F. Volk