[FIFTH THIRD FUNDS LETTERHEAD]

January 12, 2010

VIA EDGAR CORRESPONDENCE

Ms. Sheila Stout
Securities and Exchange Commission
Division of Investment Management
100 F. Street, N.E.
Washington, DC 20549

Re:   Fifth Third Funds ("Registrant")
      (File Nos. 33-24848 and 811-05669)

Dear Ms. Stout:

This letter responds to the comments on Form N-SAR for the Registrant on behalf
of the Fifth Third Institutional Government Money Market Fund, Fifth Third
Institutional Money Market Fund, Fifth Third Prime Money Market Fund and Fifth
Third U.S. Treasury Money Market Fund (each, a "Money Market Fund") filed on
March 31, 2009 and September 22, 2009 and that were provided by telephone on
January 5, 2010.

1. SEC COMMENT: In Form N-SAR, Question 74W requests that the Registrant provide
mark-to-market net asset value per share for money market funds only (to four
decimals). The Registrant currently has four money market funds. The Fifth Third
Institutional Government Money Market Fund, the Fifth Third Institutional Money
Market Fund and Fifth Third U.S. Treasury Money Market Fund each has
Institutional, Select, Preferred and Trust Shares. The Fifth Third Prime Money
Market Fund has Institutional, Class A, Class B and Class C shares. The
Commission has requested the Registrant amend each Form N-SAR for each Money
Market Fund to include the composite level mark-to-market net asset value per
share for each Money Market Fund.

RESPONSE: The Registrant left Question 74W blank for each of the Money Market
Funds since there were not enough fields to provide mark-to-market net asset
value per share for each class of each Fund. The Registrant will amend Question
74W on each Form N-SAR filing to include the composite level mark-to-market per
share for each Money Market Fund.

The Registrant reviewed Question 74W on Form N-SAR filed on March 28, 2008 and
Form N SAR filed on October 3, 2008 for each of the Money Market Funds and
confirms that the composite level market-to-market per share for each Money
Market Fund was included in the applicable response.

If you have any further comments or questions, please contact me at (513)
534-6408.

                                         Sincerely,

                                         /s/ Matthew A. Swendiman

                                         Secretary of the Registrant

cc:   S. King