UNITED STATES 

SECURITIES AND EXCHANGE COMMISSION 

WASHINGTON, D.C. 20549 

DIVISION OF 

INVESTMENT MANAGEMENT 

October 22,2008 

Stephen A. Keen 

Reed Smith LLP 

435 Sixth Avenue 

Pittsburg, PA 1521 9-1 886 

Re: Columbia Funds Series Trust- Columbia Money Market Reserves (File No. 8 1 1-09645) 

Dear Mr. Keen: 

Your letter of October 3,2008 requests our assurance that we would not recommend that 

the Commission take any enforcement action under Sections 17(a)', 1 7(d12 and 1 2(d)(313 of the 

Investment Company Act of 1940 (the "Act"), and the rules thereunder, if Columbia Money 

Market Reserves (the "Fund"), a series of the Columbia Funds Series Trust (the "Trust), and N.B. 

Funding Company LLC (the "Affiliate"), enter into the arrangement summarized below and more 

fully described in the letter. The Affiliate is a subsidiary of Bank of America Corporation (the 

"Parent"), that is the parent of the Fund's investment adviser and, therefore, an affiliated person 

of the Fund as defined in Section 2(a)(3) of the Act. 

The Fund is an open-end management investment company that is registered with the 

Commission under the Act. The Fund is a money market fund that seeks to maintain a stable net 

1 Section 17(a)(l) generally makes it unlawful for any affiliated person of a registered investment 

company, or an affiliated person of such person, acting as principal, to knowingly sell any 

security or other property to the registered investment company. 

2 Section 17(d) generally makes it unlawful for any affiliated person of a registered investment 

company, or any affiliated person of such a person, acting as principal, to effect any transaction 

in which the registered investment company is a joint or joint and several participant with such 

person in contravention of rules and regulations adopted by the Commission. 

3 Section 12(d)(3) generally makes it unlawful for any registered investment company to acquire 

any security issued by, or any interest in the business of, any broker-dealer, any person engaged 

in the business of underwriting, or an investment adviser of an investment company, or an 

investment adviser registered under the Investment Advisers Act of 1940. 
asset value per share of $1-00 and uses the amortized cost method of valuation in valuing its 

portfolio securities as permitted by rule 2a-7 under the Act. 

You state that the Fund holds in its portfolio securities that are subject to the events 

specified in Rule 2a-7(c)(6)(ii)(A) and may hold securities that become subject to such events in 

the future (any security held by the Fund that is or becomes subject to any such event is referred 

to as a "Covered Security.") You state further that the Fund's Board of Trustees or Directors, as 

applicable (the "Board''), including a majority of the trustees or directors who are not interested 

persons as that term is defined in Section 2(a)(19) of the Act, have determined with respect to 

each Covered Security currently held by the Fund that, due to unfavorable general market 

conditions, it would not be in the interests of the Fund to sell the Covered Securities at this time. 

In November 2007, after receiving assurances fiom the staff of the Division of Investment 

Management, the Fund, certain other affiliated money market funds, and the Affiliate entered 

into a capital support agreement (the "Agreement"), a form of which was provided to the staff. 

The Agreement required the Affiliate to make a cash contribution (up to a specified maximum 

amount) sufficient to restore the Fund's net asset value per share to the minimum permissible net 

asset value specified in the Agreement, if certain triggering events occurred. The Agreement was 

intended to limit the potential losses that the Fund (and the affiliated money market funds) may 

incur upon the ultimate disposition of a Covered Security. 

You now seek to amend the Agreement ("'Revised Agreement") to (a) reflect that the 

Agreement is now limited to the Fund, (b) modify the definition of a Covered Security, and (c) 

increase the contributions payable to the Fund and the maximum contribution amount specified 

in the Agreement. You state that the Revised Agreement would obligate the Affiliate to make a 

cash contribution to the Fund in any of the following circumstances (each, a "Contribution 

Event"): (i) any sale of any Covered Security by the Fund for cash in an amount less than the 

amortized cost value of the Covered Security; (ii) receipt of a final payment on any Covered 

Security in an amount less than its amortized cost value; (iii) issuance of an order by a court 

having jurisdiction over the matter discharging an issuer from liability for any Covered Security 

and providing for payments in an amount less than the amortized cost value of the Covered 

Security; or (iv) receipt of new securities that are Eligible Securities in exchange for or in 

replacement of any Covered Securities if the amortized cost value of the new securities is less 

than the amortized cost value of the Covered Securities exchanged or replaced. 

You represent with respect to the Revised Agreement that: 

(i) 	 The Agreement would obligate the Affiliate upon the occurrence of a Contribution 

Event to make a cash contribution to the Fund (up to the maximum amount in the 

Agreement) in an amount sufficient to restore the Fund's net asset value per share 

to the minimum permissible net asset value specified in the Agreement; 

(ii) 	 The Agreement would be entered into at no cost to the Fund, and the Affiliate 

would not obtain any shares from the Fund in exchange for its contribution; 
(iii) 	 The Fund will sell all the Notes it holds promptly on the business day immediately 

prior to the termination date of the Agreement, if such sale would trigger a cash 

contribution under the Agreement; and 

(iv) 	 The Board has reviewed and approved the Agreement and has determined that 

entering into the Agreement is in the best interests of the Fund and its 

shareholders. 

You state that the Affiliate does not have its own credit rating, but that the Affiliate's 

commitment under the Agreement would be guaranteed by the Parent. You represent with 

respect to the guaranty that: 

(i) 	 If the Agreement is deemed to be a security within the meaning of Section 2(a)(36) 

of the Act, it would be an Eligible Security as defined in rule 2a-7 because the 

Parent's obligations qualifj as First Tier Securities; 

(ii) 	 The Board's delegate, in accordance with rule 2a-7(c)(3)(i), has determined that 

the guaranty presents minimal credit risks with respect to the Fund; and 

(iii) 	 The Agreement would terminate promptly following a change in the Parent's 

short-term credit ratings such that the Parent's obligations no longer qualifj as 

First Tier Securities. 
On the basis of the facts and representations in your letter, we will not recommend 

enforcement action under Sections 17(a), 17(d) and 12(d)(3) of the Act, or the rules thereunder, if 

the Fund and the Affiliate enter into the arrangement summarized above and more fully described 

in your letter.4 You should note that any different facts or representations might require a 

different conclusion. Moreover, this response expresses the Division's position on enforcement 

action only and does not express any legal conclusions on the issues presented.5 

Very truly yours, 

Dalia Osman Blass 

Senior Counsel 

4 This letter confirms oral no-action relief provided by the undersigned to Stephen A. Keen on 

October 3,2008. 

5 The Division of Investment Management generally permits third parties to rely on no-action or 

interpretive letters to the extent that the third party's facts and circumstances are substantially 

similar to those described in the underlying request for a no-action or interpretive letter. 

Investment Company Act Release No. 22587 (Mar. 27, 1997) n. 20. In light of the very factspecific nature of the Fund's request, however, the position expressed in this letter applies only 

to the entities seeking relief, and no other entity may rely on this position. Other funds facing 

similar legal issues should contact the staff of the Division about the availability of no-action 

relief. 
Reed Smith LLP 

435 Sixth Avenue 

Pittsburgh, PA 1521 9-1886 

+I 4122883131 

Stephen A. Keen Fax+$ 412288 3063 

Direct Phone: +I 412 288 1567 

Email: skeen@reedsmith.com 

October 3,2008 

Investment Company Act of 1940-

Sections 12(d)(3), 17(a)(l), and 17(d) 

Mr. Robert E. Plaze 

Associate Director 

U.S. Securities and Exchange Commission (SEC) 


100 F Street, N.E. 


Washington, DC 20549 


Re: Columbia Money Market Reserves, a series of Columbia Funds Series Trust (the "Fund") 

Dear Mr. Plaze: 

We are writing on behalf of NB Funding Company LLC (the "Affiliate"), an affiliated person of 

the investment adviser of the above-referenced Funds. We seek assurance from the staff of the Division 

of Investment Management ("Division") that it will not recommend enforcement action to the 

Commission under Sections 12(d)(3), 17(a)(l) or 17(d) of the Investment Company Act of 1940 ("1940 

Act"), or the rules thereunder, if the Fund and the Affiliate enter into the arrangement described below. 

The Fund is registered with the Commission under the 1940 Act as an open-end management 

investment company. The Fund, as a money market fund, seeks to maintain a stable net asset value per 

share of $1.00, and each uses the amortized cost method of valuation in valuing its portfolio securities. 

The Affiliate is a subsidiary of Bank of America Corporation (the "Parent") that is the parent of the 

Fund's investment adviser. The Parent has received ratings in the highest short-term rating category 

from all nationally recognized statistical rating organizations ("NRSROs") that rate its obligations. 

The Fund currently holds securities that are subject to the events specified in 

Rule 2a-7(c)(6)(ii)(A) and may hold securities that become subject to such events in the fiture (any 

security held by the Fund that is or becomes subject to any such event, is referred to as a "Covered 

Security.") With respect to each Covered Security currently held by the Fund, in accordance with 

Rule 2a-7(c)(6)(ii), the Fund's board of trustees or directors, as applicable (the "Board"), including a 

majority of the trustees or directors who are not "interested persons" as that term is defined in Section 

2(a)(19) of the 1940 Act ("Independent Directors"), have determined that, due to unfavorable general 

market conditions, it currently is not in the interest of the Fund to sell such Covered Securities. 

To limit the potential losses that the Fund may incur upon the ultimate disposition of a Covered 

Security, the Affiliate proposes to enter into a Restated Capital Support Agreement (the "Agreement"), 

at no cost to the Fund, that would prevent any losses realized on the Covered Securities from causing the 

Fund's market based net asset value per share ("NAV") to fall below the Minimum NAV Per Share 

specified in the Agreement. The Agreement amends and restates in its entirety the Capital Support 

Agreement, dated November 14, 2007 (as restated and amended since that date, the "Original 

Agreement"), among the Affiliate, the Fund and certain other affiliated money market funds. The 

NEW YORK * LONDON* CHICAGO 6 PARIS * LOS ANGELES *WASHINGTON, D.C. tSAN FRANCISCO +PHILADELPHIA + PITTSBURGH+ OAKLAND 

MUNICH 4 ABU DHABl * PRINCETON e NORTHERN VIRGINIA e WlLMlNGTON * BIRMINGHAM + DUBAl * CENTURY CITY * RICHMOND *GREECE 
Mr. Robert E. Plaze 

October 3,2008 

Page 2 

Division has previously taken a no-action position with respect to the Agreement in response to a 

request dated November 14, 2007. The Agreement amends the Original Agreement to (a) reflect that the 

Agreement is now limited to the Fund, (b) modify the definition of a Covered Security, and (c) increase 

the contributions payable to the Fund and the Maximum Contribution Amount specified in the 

Agreement. We are requesting that the Division affirm its no-action position with respect to these 

amendments. 

As with the Original Agreement, upon a sale or other ultimate disposition of a Covered 

Security,l the Agreement would obligate the Affiliate to make a cash contribution to the Fund (up to the 

Maximum Contribution Amount) sufficient to restore the Fund's NAV to the Minimum NAV Per Share. 

The Affiliate would not obtain any shares or other consideration from the Fund for its contribution; and 

the Fund would agree to retain the contribution and not to include it in any dividends or distributions. 

The Agreement will be in the form attached to this letter. The Agreement will terminate on 

December 13, 2008. The Fund is obligated to sell the Covered Securities on the business day 

immediately prior to the termination of the Agreement if the sale would require the Affiliate to make a 

payment to the Fund. 

The Parent will provide the Fund with a written guarantee of the Affiliate's obligation to make 

contributions under the Agreement. The Parent's guarantee will be unconditional and will continue until 

the termination of the Agreement. 

The Board has been presented with and reviewed a draft form of the Agreement and has 

determined the proposed transaction is in the best interests of the Fund and its shareholders.. In 

addition, the Board's delegate has determined, based on the Parent's guarantee, that the Affiliate's 

obligations are Eligible Securities as defined in Rule 2a-7(a)(10); and that the Affiliate's obligations 

present minimal credit risks under Rule 2a-7(3)(c)(i). The Board has therefore authorized, subject to 

receipt of the requested no-action position, the Fund to accept the Agreement. 

The Board will direct the Fund to sell the Covered Securities if, following any downgrading of 

the Parent's credit ratings, the Affiliate's obligations would no longer qualify as First Tier Securities and 

that such sale would require the Affiliate to make a payment to the Fund. If such sale would not require 

such payment, the Agreement would terminate. 

The Affiliate is an "affiliated person" or an "affiliated person of an affiliated person" under 

Section 2(a)(3) of the 1940 Act because it and the investment adviser to each of the Fund are common 

subsidiaries of the Parent. The issuance of the Agreement to the Fund may be subject to Section 17(a)(l) 

of the 1940 Act, which makes it unlawful for any affiliated person of a registered investment company 

(or any affiliated person of such person) acting as principal to knowingly sell any security or other 

property to the investment company. The proposed arrangement may also fall within Section 17(d) of 

the 1940 Act, which makes it unlawful for any affiliated person (or any affiliated person of such person) 

of a registered investment company to affect any transaction in which such registered investment 

company is a joint, or joint and several participant, with such person. 

Contributions may be required under the Agreement in the event of (i) a sale of any Covered 

Securities, (ii) receipt of final payment on any Covered Securities, (iii) a court order discharging liability 

for any Covered Securities and (iv) an exchange of Covered Securities for other Eligible Securities, in 

each case where the amount of payments received andlor the market value of the Eligible Securities 

received is less than the amortize cost value of the Covered Securities. 

1 
Mr. Robert E. Plaze 

October 3,2008 

Page 3 

The Parent's operations include subsidiaries that act as brokeddealers and investment advisers 

registered with the Commission. The issuance of the Agreement by the Affiliate to the Fund therefore 

may be subject to Section 12(d)(3) of the 1940 Act, which makes it unlawful for a registered investment 

company to purchase any security issued by or any other interest in the business of any person who acts 

as a broker, dealer or registered investment adviser. The Fund could not rely upon the exemption 

provided under Rule 12d3-1 because the exemption does not extend to affiliated persons of the Fund's 

investment adviser. 

On behalf of the Fund, the Affiliate and the Parent, we hereby request that the Division staff give 

its assurance that it will not recommend the Commission take enforcement action against the Fund, the 

Affiliate or the Parent under Section 17(a)(l), Section 17(d) or Section 12(d)(3) of the 1940 Act, or the 

rules thereunder, if the Affiliate and the Fund enter into the Agreement, and the Parent guarantees the 

Agreement, as described above. 

If you have any questions or other communications concerning this matter, please call the 

undersigned at (412) 288-1567. 

Very truly yours, 


Stephen A. Keen 


Reed Smith LLP 


Attachment 

SAK:rnr