90 State House Square Hartford, CT 06103-3702 +1 860 524 3999 Main +1 860 524 3930 Fax www.dechert.com

April 22, 2020

Via EDGAR

Alison White, Esq.

Senior Counsel

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, NE
Washington, DC 20549

Post-Effective Amendment No. 56

Dear Ms. White:

On behalf of the Praxis Mutual Funds (the “Registrant”) and each of its series (a “Fund”), I am responding to the comments you provided to me via telephone on April 1, 2020, regarding post-effective amendment no. 56 to the Registrant’s registration statement filed on Form N-1A pursuant to Rule 485(a) under the Securities Act of 1933, as amended.

Response: COVID19-related related risk disclosure will be added.

Response: Completed fee tables, as they will appear in the Registrant’s 485(b) filing, are included as an exhibit to this letter.

Response: Management has reviewed the acquired fund fees for all Funds and has concluded that the indirect expenses of securities of other mutual funds held by each Fund (excluding the Genesis Portfolios) is less than 1 basis point for the fiscal year 2019. With the exception of the Genesis Portfolios, investments in other mutual funds is not a principal investment strategy for any Fund.

U.S. Securities and Exchange Commission 04/21/20 Page 2

Response: The requested change will be made.

Response: The requested change will be made.

Response: The requested disclosure will be added to the statutory section of the prospectus. The Registrant does not regard this level of detail about the indexes as necessary or appropriate for the summary section. None of the Funds currently uses derivatives to track its benchmark index.

Response: The International Index Fund currently uses ADRs for this purpose. The other Index Funds do not use other investments for this purpose. In light of the comment, the disclosure for the International Index Fund will be revised as follows (deletions stricken, additions underlined):

“Under normal circumstances, the Fund invests at least 80 percent of the value of its assets in securities of, and investments related to, issuers in the Fund’s benchmark index. Typically, the Fund invests substantially more than 80 percent of the value of its assets in such securities and investments. Investments related to the benchmark index include in which the Fund invests consist of American Depositary Receipts (ADRs), which are equity securities that represent shares of foreign companies in the index.”

The disclosure for the other Index Funds will be revised as follows (deletions stricken, additions underlined):

“Under normal circumstances, the Fund invests at least 80 percent of the value of its assets in securities of, and investments related to, issuers in the Fund’s benchmark index. Typically, the Fund invests substantially more than 80 percent of the value of its assets in such securities of issuers in its benchmark index.”

U.S. Securities and Exchange Commission 04/21/20 Page 3

Response: The defining characteristic of an index fund is that it seeks to track the performance of its benchmark index, and each Index Fund (for purposes of this response, also referred to as a “Fund”) does just that, as reflected in its name. As further discussed below, in our view:

Principal Investment Strategies: The Funds have substantively identical disclosures about their principal investment strategies, with variations attributable to the particular benchmark index each seeks to track and the specific types of securities in which each invests. For example, the Praxis Value Index Fund has the following Principal Investment Strategies disclosure (emphasis added):

The Fund invests primarily in U.S. equity securities and seeks to reflect the performance of the U.S. large capitalization value equities market, as measured by the S&P 500 Value Index, its benchmark index. Under normal circumstances, the Fund invests at least 80 percent of the value of its assets in securities of, and investments related to, issuers in the Fund’s benchmark index. Typically, the Fund invests substantially more than 80 percent of the value of its assets in such securities. The benchmark index consists of those stocks in the S&P 500 Index determined to exhibit the strongest “value” characteristics based on book value to price, earnings to price and sales to price ratios. The Fund seeks to invest in companies aligned with the Stewardship Investing core values, as discussed below. In addition, the Adviser uses optimization techniques, including ESG factors, to select securities according to their contribution to the Fund’s overall objective, while seeking to replicate the characteristics of the index, including risk and return characteristics.

Legal Basis for Name and Principal Investment Strategies: Each Fund’s name and 80% policy comply with Section 35(d) and Rule 35d-1. Section 35(d) provides in pertinent part that is unlawful for any registered investment company to adopt as part of its name any word that the Commission finds materially misleading or deceptive and authorizes the Commission to define such names by rule, regulation or order. Rule 35d-1 provides in pertinent part that a name suggesting a registered investment company focuses its investments in a particular type of investment would be materially deceptive and misleading unless it has adopted a policy to invest, under normal circumstances, at least 80% of the value of its net assets, plus the amount of any borrowings for investment purposes, in the particular type of investment suggested by the name. Because each Fund uses “index” in its name, it has adopted a policy to invest, under normal circumstances, at least 80% of the value of its net assets plus borrowings for investment purposes (“assets”) in the particular type of investments suggested by its name, in this case, constituents of its benchmark index. This 80% policy meets the requirements of Rule 35d-1.

U.S. Securities and Exchange Commission 04/21/20 Page 4

Each Fund’s name and 80% policy also comply with published Commission guidance relating to index funds. In the release adopting Rule 35d-1, the Commission stated: “Index Funds, for example, generally would be expected to invest more than 80% of their assets in investments connoted by the applicable index.” In accordance with this guidance, each Fund consistently invests substantially more than 80% of its assets in securities of constituents of its benchmark index. As of December 31, 2019, for example, the percentage of the value of each Fund’s assets that was invested in securities (in the case of the International Index Fund, including ADRs) of issuers in the Fund’s benchmark index, was as follows:

Each Fund’s name conveys its intention to seek to track the performance of its benchmark index and is therefore helpful to investors and consistent with its principal investment strategies. Each Fund’s Principal Investment Strategies section provides additional detail about how the Fund seeks to track the performance of its benchmark index, which complements its 80% policy and is consistent with its use of “index” in its name. This disclosure makes clear that while the Fund does not seek to hold every constituent of its benchmark index, it invests substantially all of its assets index constituents (or related securities) and seeks to replicate the performance of the index. This complies fully with Form N-1A, the Investment Company Act, applicable rules and published guidance.

Each Fund’s name is consistent with industry practices and investor expectations. We are not aware of any legal requirement for a mutual fund that uses “index” in its name to adopt a policy to hold every constituent of the applicable index and observe that such a policy, except in certain narrow circumstances, can be inefficient and impractical. In our experience, while some index-based mutual funds seek to match or replicate the entire composition of the indexes whose performance they seek to track (that is, to hold all of the index constituents in the same or approximately the same proportion as the index), many index-based mutual funds, like the Funds, seek to track or replicate the performance of their indexes by holding an optimized sub-set of components of the index. Constructing an index-based portfolio in this manner is commonly described as using “optimization” or “sampling.” Optimization/sampling is widely used by index funds because holding every index component is inefficient, and for certain asset classes and indexes, impracticable. Given the widespread use optimization/sampling by index funds, we believe its use is consistent with investor expectations for mutual funds that hold themselves out as index funds. With regard to the Funds in particular, those expectations are reinforced with clear and conspicuous disclosure in the Funds’ Principal Investment Strategies sections.

Index-based mutual funds following both approaches routinely use “index” in their names. Inclusion of more specific terms, such as “optimized index” with regard to the former, or “replicated index” with regard to the latter, are less common and neither is legally required.

Application of ESG factors does not alter the above conclusions. Like any other index-based mutual fund using an optimization/sampling strategy, each Fund is accurately described as an index fund. As is common for index funds, each Fund’s optimization process is used to construct a portfolio that seeks to replicate the performance of the applicable benchmark index. Application of ESG factors as a component of each Fund’s optimization process, a process that is used to construct portfolios designed to track its benchmark index, does not alter a Fund’s character as an index fund any more than a non-ESG motivated sampling method used by another fund complex would disqualify its optimized index funds from identifying themselves as index funds.

U.S. Securities and Exchange Commission 04/21/20 Page 5

In this regard, construction of the Fund’s portfolio is consistent with any other index-based mutual fund that utilizes an optimization or sampling strategy in that a proprietary method is used to build a portfolio from a sub-set of the index constituents that is designed to closely track the performance of the index. The fact that a Fund excludes certain index constituents before applying the optimization methodology to build the portfolio to track the performance of the index does not in any way imply that this Fund is not aptly described as an index fund.

Changing a Fund’s name to modify or omit “index” would be less helpful to investors than continuing to use the existing name. Adding “optimized” or another modifier before “index” would add complexity and length to each Fund’s name, while removing “index” would remove a helpful signal to investors about each Fund’s principal investment strategies. Accordingly, in the Registrant’s view, neither change is preferable to the existing name of each Fund. In addition, making any type of change to a Fund’s name would require deployment of resources to inform investors and financial intermediaries about the change. The Registrant believes that would be a challenging messaging campaign since Fund shareholders and intermediaries understand the investment strategies for these Funds and are familiar with their current names, and that any of the suggested name changes would be perceived, at best, as a neutral event.

For these reasons, we respectfully submit that the existing name of each Fund is consistent with applicable legal requirements, and accordingly, that the existing name of each Fund is appropriate.

Response: The requested change will be made. The expense limitation agreement and footnote disclosure will be revised to reflect that the applicable measurement date is the date or month of the waiver/reimbursement and not the end of that year.

Response: The requested change will be made. The reference to a composite benchmark will be deleted from the preamble.

U.S. Securities and Exchange Commission 04/21/20 Page 6

Response: The requested change will be made. The footnote or table will be revised for each Portfolio as appropriate.

Response: As implied by the third sentence in that paragraph, the list is provided to the portfolio managers of the other Funds. In light of the comment, the third and fourth sentences will be revised as follows (deleted stricken, added underlined):

“Companies on this list are summarily restricted from all passively-managed Praxis Mutual Funds. This list is provided to the portfolio managers of the Praxis index Funds, who are restricted from purchasing excluded securities for these Funds. Due to the discretionary component of its active investment strategy, this list, along with related ESG company information and interaction with the Adviser’s Stewardship Investing staff, will be provided to the portfolio managers of the Praxis Impact Bond Fund on an advisory basis to further inform their investment management process.”

Response: All of the principal risks will be disclosed separately in the Principal Investment Risks section for each Fund.

Response: None of the Funds currently uses derivatives for purposes of meeting its 80% test.

Response: The requested change will be made.

Response: The requested change will be made.

U.S. Securities and Exchange Commission 04/21/20 Page 7

Response: The suggested change will be made.

Response: The requested change will be made.

Response: The requested change will be made.

Response: The Registrant’s principal financial officer also serves as its principal accounting officer. The signature line will be revised to add principal accounting officer.

Please contact me at the above number if you have any questions.

Very truly yours,

/s/ Anthony H. Zacharski

Anthony H. Zacharski

Fund Counsel, Praxis Mutual Funds

Exhibit

Praxis Impact Bond Fund

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy and hold shares of the Fund. In addition to the fees and expenses described below, you may be required to pay a fee to a broker or other financial firm on purchases and sales of Class I shares of the Fund. You may qualify for sales charge discounts if you and your family invest, or agree to invest in the future, at least $50,000 in the Praxis Mutual Funds. More information about these and other discounts is available from your financial professional and in the section titled “Sales Charge Reductions” on page [57] of the Fund’s prospectus.

Example

This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds.

The Example assumes that you invest $10,000 in the Fund for the time period indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5 percent return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

Portfolio Turnover: The Fund pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover may indicate higher transaction costs and may result in higher taxes when Fund shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the Example, affect the Fund’s performance. During the most recent fiscal year, the Fund’s portfolio turnover rate was 17.58 percent of the average value of its portfolio.

Praxis International Index Fund

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy and hold shares of the Fund. In addition to the fees and expenses described below, you may be required to pay a fee to a broker or other financial firm on purchases and sales of Class I shares of the Fund. You may qualify for sales charge discounts if you and your family invest, or agree to invest in the future, at least $50,000 in the Praxis Mutual Funds. More information about these and other discounts is available from your financial professional and in the section titled “Sales Charge Reductions” on page [57] of the Fund’s prospectus.

Example

This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds.

The Example assumes that you invest $10,000 in the Fund for the time period indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5 percent return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

Portfolio Turnover: The Fund pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover may indicate higher transaction costs and may result in higher taxes when Fund shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the Example, affect the Fund’s performance. During the most recent fiscal year, the Fund’s portfolio turnover rate was 20.61 percent of the average value of its portfolio.

Praxis Value Index Fund

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy and hold shares of the Fund. In addition to the fees and expenses described below, you may be required to pay a fee to a broker or other financial firm on purchases and sales of Class I shares of the Fund. You may qualify for sales charge discounts if you and your family invest, or agree to invest in the future, at least $50,000 in the Praxis Mutual Funds. More information about these and other discounts is available from your financial professional and in the section titled “Sales Charge Reductions” on page [57] of the Fund’s prospectus.

Example

This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds.

The Example assumes that you invest $10,000 in the Fund for the time period indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5 percent return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

Portfolio Turnover: The Fund pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover may indicate higher transaction costs and may result in higher taxes when Fund shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the Example, affect the Fund’s performance. During the most recent fiscal year, the Fund’s portfolio turnover rate was 39.06 percent of the average value of its portfolio.

Praxis Growth Index Fund

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy and hold shares of the Fund. In addition to the fees and expenses described below, you may be required to pay a fee to a broker or other financial firm on purchases and sales of Class I shares of the Fund. You may qualify for sales charge discounts if you and your family invest, or agree to invest in the future, at least $50,000 in the Praxis Mutual Funds. More information about these and other discounts is available from your financial professional and in the section titled “Sales Charge Reductions” on page [57] of the Fund’s prospectus.

Example

This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds.

The Example assumes that you invest $10,000 in the Fund for the time period indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5 percent return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

Portfolio Turnover: The Fund pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover may indicate higher transaction costs and may result in higher taxes when Fund shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the Example, affect the Fund’s performance. During the most recent fiscal year, the Fund’s portfolio turnover rate was 32.33 percent of the average value of its portfolio.

Praxis Small Cap Index Fund

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy and hold shares of the Fund. In addition to the fees and expenses described below, you may be required to pay a fee to a broker or other financial firm on purchases and sales of Class I shares of the Fund. You may qualify for sales charge discounts if you and your family invest, or agree to invest in the future, at least $50,000 in the Praxis Mutual Funds. More information about these and other discounts is available from your financial professional and in the section titled “Sales Charge Reductions” on page [57] of the Fund’s prospectus.

Example

This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds.

The Example assumes that you invest $10,000 in the Fund for the time period indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5 percent return each year and that the Fund’s operating expenses remain the same. This example reflects the net operating expenses with fee waiver for the one-year contractual period and the total operating expenses without fee waiver for the remaining periods shown below. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

Portfolio Turnover: The Fund pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover may indicate higher transaction costs and may result in higher taxes when Fund shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the Example, affect the Fund’s performance. During the most recent fiscal year, the Fund’s portfolio turnover rate was 21.59 percent of the average value of its portfolio.

Praxis Genesis Conservative Portfolio

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy and hold shares of the Portfolio. You may qualify for sales charge discounts if you and your family invest, or agree to invest in the future, at least $50,000 in the Praxis Mutual Funds. More information about these and other discounts is available from your financial professional and in the section titled “Sales Charge Reductions” on page [57] of the Portfolio’s prospectus.

Example

This Example is intended to help you compare the cost of investing in the Portfolio with the cost of investing in other mutual funds.

The Example assumes that you invest $10,000 in the Portfolio for the time period indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5 percent return each year and that the Portfolio’s operating expenses remain the same. This example reflects the net operating expenses with fee waiver for the one-year contractual period and the total operating expenses without fee waiver for the remaining periods shown below. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

Portfolio Turnover: The Portfolio pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover may indicate higher transaction costs and may result in higher taxes when Portfolio shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the Example, affect the Portfolio’s performance. During the most recent fiscal year, the Portfolio’s portfolio turnover rate was 10.10 percent of the average value of its portfolio.

Praxis Genesis Balanced Portfolio

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy and hold shares of the Portfolio. You may qualify for sales charge discounts if you and your family invest, or agree to invest in the future, at least $50,000 in the Praxis Mutual Funds. More information about these and other discounts is available from your financial professional and in the section titled “Sales Charge Reductions” on page [57] of the Portfolio’s prospectus.

Example

This Example is intended to help you compare the cost of investing in the Portfolio with the cost of investing in other mutual funds.

The Example assumes that you invest $10,000 in the Portfolio for the time period indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5 percent return each year and that the Portfolio’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

Portfolio Turnover: The Portfolio pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover may indicate higher transaction costs and may result in higher taxes when Portfolio shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the Example, affect the Portfolio’s performance. During the most recent fiscal year, the Portfolio’s portfolio turnover rate was 9.43 percent of the average value of its portfolio.

Praxis Genesis Growth Portfolio

Fees and Expenses

This table describes the fees and expenses that you may pay if you buy and hold shares of the Portfolio. You may qualify for sales charge discounts if you and your family invest, or agree to invest in the future, at least $50,000 in the Praxis Mutual Funds. More information about these and other discounts is available from your financial professional and in the section titled “Sales Charge Reductions” on page [57] of the Portfolio’s prospectus.

Example

This Example is intended to help you compare the cost of investing in the Portfolio with the cost of investing in other mutual funds.

The Example assumes that you invest $10,000 in the Portfolio for the time period indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5 percent return each year and that the Portfolio’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

Portfolio Turnover: The Portfolio pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover may indicate higher transaction costs and may result in higher taxes when Portfolio shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the Example, affect the Portfolio’s performance. During the most recent fiscal year, the Portfolio’s portfolio turnover rate was 7.72 percent of the average value of its portfolio.