CUSTOMER IDENTIFICATION SERVICES AMENDMENT

     This Customer Identification Services Amendment (this "Amendment") amends,
as of the 1st day of October, 2003 (the "Effective Date"), the Transfer Agency
Services Agreement, dated as of November 7, 1997, between Churchill Tax-Free
Trust (the "Fund") and PFPC Inc. ("PFPC") (the "Agreement").

     For valuable consideration, the receipt and sufficiency of which the
parties hereto hereby acknowledge, the Fund and PFPC hereby agree as follows:

     Section 1 (Addition of CIP Services section to the Agreement). As of the
Effective Date, the Agreement shall be amended by the addition of the following
as the new final section of the agreement:

          "CIP Services. To help the Fund comply with its Customer
          Identification Program (which the Fund is required to have under
          regulations issued under Section 326 of the USA PATRIOT Act) PFPC will
          do the following:

          (a)  Implement procedures under which new accounts in the Fund are not
               established unless PFPC has obtained the name, date of birth (for
               natural persons only), address and government-issued
               identification number (collectively, the "Data Elements") for
               each corresponding Customer (as defined in 31 CFR 103.131).

          (b)  Use collected Data Elements to attempt to reasonably verify the
               identity of each new Customer promptly before or after each
               corresponding new account is opened. Methods may consist of
               non-documentary methods (for which PFPC may use unaffiliated
               information vendors to assist with such verifications) and
               documentary methods (as permitted by 31 CFR 103.131), and may
               include procedures under which PFPC personnel perform enhanced
               due diligence to verify the identities of Customers the
               identities of whom were not successfully verified through the
               first-level (which will typically be reliance on results obtained
               from an information vendor) verification process(es).

          (c)  Record the Data Elements and maintain records relating to
               verification of new Customers consistent with 31 CFR
               103.131(b)(3).

          (d)  Regularly report to the Fund about measures taken under (a)-(c)
               above.

          (e)  Provide annually or upon the reasonable request of the Fund a
               certification that PFPC has, to the best of its knowledge,
               complied with its obligations under this Amendment.

          (f)  If PFPC provides services by which prospective Customers may
               subscribe for shares in the Fund via the Internet or telephone,
               work with the Fund to notify prospective Customers, consistent
               with 31 CFR 103.(b)(5), about the Fund's CIP.

          (g)  Set forth on a separate fee schedule compensation amounts due for
               these CIP Services.

          Notwithstanding anything to the contrary, and without expanding the
          scope of the express language above, PFPC need not collect the Data
          Elements for (or verify) prospective customer (or accounts) beyond the
          requirements of relevant regulation (for example, PFPC will not verify
          customers opening accounts through NSCC) and PFPC need not perform any
          task that need not be performed for the Fund to be in compliance with
          relevant regulation.

          The Fund hereby represents and warrants that each of the portfolios
          serviced by PFPC, and each legal entity of which such portfolio is a
          part, has, and will at all times during which this Agreement is in
          effect maintain in place, a written agreement with each such other
          portfolio and entity, under which all such parties may rely upon the
          Customer Identification Programs of any other with respect to
          prospective investors who are then existing customers of such other.
          Given such inter-company (or inter-fund) agreement(s), PFPC need not
          perform steps (a)-(f) above with respect to any subscriber who is then
          a customer of any other fund within the same "fund family" as the
          Fund."

     Section 2 (General provisions). This Amendment contains the entire
understanding between the parties with respect to the services contemplated
hereby. Except as expressly set forth herein, the Agreement shall remain
unaffected hereby.

     IN WITNESS WHEREOF, the parties hereto have caused this Amendment to be
executed by their duly authorized officers, as of the day and year first above
written.


CHURCHILL TAX-FREE TRUST



       /s/ Diana P. Herrmann
By: __________________________________________
Name:     Diana P. Herrmann
Title:    President



PFPC INC.


       /s/ Wayne D. Weaver
By: ________________________________________
Name:      Wayne D. Weaver
Title:     Managing Director