STAR FUNDS

                              Federated Investors
                           Federated Investors Tower
                      Pittsburgh, Pennsylvania 15222-3779
                                 (412)288-1900


                                 July 10, 1996


EDGAR Operations Branch
U.S. Securities and Exchange Commission
Division of Investment Management
450 Fifth Street, Northwest
Washington, D.C. 20549


      RE:      STAR FUNDS - CIK No. 846030
          Request for Withdrawal of Amendment
          to Registration Statement on Form N-1A;
          1933 Act File No. 33-26915
          1940 Act File No. 811-5762


Ladies and Gentlemen:

      On behalf of Star Funds (the "Trust"), I hereby submit this application
for withdrawal of Post-Effective Amendment No. 28 filed on May 28, 1996, under
the Securities Act of 1933 (the "Act") to the Trust's Registration Statement on
Form N-1A.
      The Amendment is being withdrawn because it was inadvertently filed with
the incorrect signature page. The Trust intends to re-file the Amendment
correctly pursuant to Rule 485(a) of the Act. Please issue an order with respect
to this application for withdrawal at the earliest date the Staff deems
appropriate.

      Pursuant to the requirements of Rule 477(a) of the Act, this application
for withdrawal of the Amendment has been signed by the Secretary of the Trust
this 10th day of July, 1996.

      If you have any questions regarding this application for withdrawal,
please call Jean Bittner, Legal Assistant, at (412)288-1940.


                              Very truly yours,



                              /s/ C. Grant Anderson
                              C. Grant Anderson
                              Secretary