ROPES & GRAY LLP
                                ONE METRO CENTER
                              700 12TH STREET, N.W.
                                    SUITE 900
                            WASHINGTON, DC 20005-3948

                   WRITER'S DIRECT DIAL NUMBER: (617) 951-7910


June 29, 2007

BY EDGAR

Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Linda Stirling

Re:   Fifth Third Funds (the "Trust") (Registration Nos. 33-24848 and 811-05669)
      Post-Effective Amendment No. 60/61 to the Registration Statement


Ladies and Gentlemen:

This letter is in response to oral comments provided to the undersigned by Linda
Stirling of the staff of the Securities and Exchange Commission (the
"Commission") on May 24, 2007, regarding the Fifth Third Large Cap Core Fund
(the "Fund") Post-Effective Amendment No. 60 to Fifth Third's Registration
Statement under the Securities Act of 1933, as amended (the "1933 Act") and
Amendment No. 61 to Fifth Third's Registration Statement under the Investment
Company Act of 1940, as amended (the "1940 Act") pursuant to Section 485(a) of
the 1933 Act and the 1940 Act. These comments and responses thereto are set
forth below.

         1.       Comment: Under "Principal Investment Strategies" on page two
                  of the prospectus, the last sentence of the fourth paragraph
                  reads as follows: "The Advisor will typically maintain certain
                  minimum and maximum sector and position weightings relative to
                  the S&P 500 Index and will monitor risk statistics relative to
                  the S&P 500 Index." Please clarify what is meant by the phrase
                  "relative to" in both instances in which it is used (e.g.,
                  replicating the Index?)

Response: We have revised the last sentence of the fourth paragraph on page two
of the prospectus to read as follows: "The Advisor typically seeks to monitor
and control the industry sector weightings of the Fund and the Fund's exposure
to individual equity securities, allowing them to differ only moderately from
the industry sector weightings and position weightings of the S&P 500 Index. By
doing so, the Advisor seeks to limit the Fund's volatility to that of the
overall market, as represented by the S&P 500 Index."



Securities and Exchange Commission        -2-                      June 29, 2007

         2.       Comment: The fee table lists the total operating expenses for
                  Class A shares, after waiver, as 1.47%. Footnote 5, however,
                  states that the maximum total annual fund operating expenses,
                  after waiver, is limited to 1.17% These two numbers need to be
                  reconciled.

Response: The last sentence of Footnote 5 addresses the discrepancy between the
numbers by indicating that expenses after waivers are expected to exceed the
applicable limitation because dividends on short sales are excluded.
Nonetheless, to further clarify, we have moved the final sentence of the
footnote so that it directly follows the first sentence (which references the
expense caps). Further, we have expanded on the last sentence so that it
explicitly states that, as a result of the exclusion of dividend expenses,
expected total operating expenses after waivers are 1.47%, 2.22%, 2.22%, and
1.72% for Class A, Class B, Class C, and Advisor Shares, respectively. A
corresponding change was made for Institutional Shares in the Institutional
Shares prospectus.

         3.       Comment: There is a typo in the disclosure about Michael
                  Wayton's business experience (indicating he has 412 years as a
                  quantitative analyst).

Response: The typo is a product of the Edgarization process and difficulties
converting symbols (e.g., "1/2"). The correct number of years--4 1/2-- is listed
in the prospectuses.


As requested, officers of the Trust have instructed us to acknowledge the
following: (i) the Trust is responsible for the adequacy and accuracy of the
disclosure in the Registration Statement; (ii) staff comments or changes to
disclosure in response to staff comments in the filings reviewed by the staff do
not foreclose the Commission from taking any action with respect to the
Registration Statement; and (iii) the Trust 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. As indicated in the Commission's
June 24, 2004 release regarding the public release of comment letters and
responses, you are requesting such acknowledgements from all companies whose
filings are being reviewed, and this request and these acknowledgements should
not be construed as suggesting that there is an inquiry or investigation or
other matter involving the Trust.


Very truly yours,

/s/ Mary Beth Constantino

Mary Beth Constantino



Securities and Exchange Commission        -3-                      June 29, 2007

cc:     Alan G. Priest
        Alyssa Albertelli
        Shannon Gotfrit