First American Mutual Funds · 485BPOS · On 1/28/94 · EX-99.OPINION

Filed On 1/28/94   ·   SEC Files 33-49087, 811-07049   ·   Accession Number 890189-94-3

Post-Effective Amendment
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 485BPOS     Form Document                                        273± 1,095K 
 2: EX-99.CONSENT  Auditor's Consent                                   1      5K 
 3: EX-99.OPINION  Donnelly's Opinion                                  1      8K 

EX-99.OPINION   ·   Donnelly's Opinion

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Exhibit No. 18 under Form N-1A                                                  

   HOUSTON, HOUSTON & DONNELLY
ATTORNEYS AT LAW        
                  2510 CENTRE CITY TOWER
WILLIAM McC. HOUSTON        PITTSBURGH, PA.  15222                              
FRED CHALMERS HOUSTON, JR.            __________                                
THOMAS J. DONNELLY                                                              
JOHN F. MECK                (412) 471-5828            FRED CHALMERS HOUSTON     
                FAX (412) 471-0736             (1914 - 1971)

MARIO SANTILLI, JR.                                                             
THEODORE M. HAMMER                                                              

January 24, 1994                

The Boulevard Funds                                                             
Federated Investors Tower                                                       
Pittsburgh, PA  15222-3779                                                      

Gentlemen:                                                                      

As counsel to The Boulevard Funds ("Trust") we have reviewed          
Post-effective Amendment No. 2 to the Trust's Registration                      
Statement to be filed with the Securities and Exchange Commission               
under the Securities Act of 1933 (File No. 33-49087).  The                      
subject Post-effective Amendment will be filed pursuant to                      
Paragraph (b) of Rule 485 and become effective pursuant to said                 
Rule immediately upon filing.                                                   

Our review also included an examination of other relevant             
portions of the amended 1933 Act Registration Statement of the                  
Trust and such other documents and records deemed appropriate.                  
On the basis of this review we are of the opinion that                          
Post-effective Amendment No. 2 does not contain disclosures which               
would render it ineligible to become effective pursuant to                      
Paragraph (b) of Rule 485.                                                      

We hereby consent to the filing of this representation                
letter as a part of the Trust's Registration Statement filed with               
the Securities and Exchange Commission under the Securities Act                 
of 1933 and as part of any application or registration statement                
filed under the Securities Laws of the States of the United                     
States.                                                                         

       Very truly yours,

                 Houston, Houston & Donnelly

             By:  Thomas J. Donnelly

TJD:smg                                                                         

Dates Referenced Herein   and   Documents Incorporated By Reference

This 485BPOS Filing		Date		Other Filings
		1/24/94
Filed On / Filed As Of / Effective As Of		1/28/94		NSAR-B
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