Correspondence - Form CORRESP

Securities and Exchange Commission

VIA EDGAR

450 Fifth Street, N.W.

Judiciary Plaza

Washington, D.C. 20548

Timothy Plan., File Nos. 811-08228 and 033-73248, Sarbanes-Oxley Review of Financial statements and Related items.

You noted that many of the Timothy Plan Traditional Funds invest in other affiliated Funds in the Trust. You further noted that the Funds that are investing in affiliated Trust Funds are purchasing Class A shares, sales loads waived. You asked the Trust to explain why the Funds are purchasing Class A shares instead of less expensive Class I shares.

You noted that on page 6 of the September 30, 2021 Annual Report, the Management Discussion of Fund Performance ("MDFP") for the Large/Mid Cap Growth Fund references gross return. In future filings, please ensure that the MDFP discloses net returns.

You noted that on page 5 of the December 31, 2020 Annual Report, the disclosed index for the Timothy Plan International ETF incudes the word "net". However, on page 15 of the report, the word "net" is not included in the disclosure. Please explain the discrepancy.

You noted that the MDFP letters for the Strategic Growth Fund and the Strategic Growth Variable Fund did not include discussion reflecting the strategies and techniques that impacted the relevant Fund's performance, as required under Item 27(b)(7) of Form N-1A. Further, the discussion related to the equity portion of the Growth & Income Fund also did not include discussion reflecting the strategies and techniques that impacted the relevant Fund's performance, as required under Item 27(b)(7) of Form N-1A.

You noted that the performance graphs and table for the ETF's in the December 31, 2020 Annual Report did not include disclosures required under Item 27(b)(7)(2)(B).

You noted that the table showing the growth of $10,000 for the ETF's in the December 31, 2020 Annual Report references Class A Shares. Since the ETF's do not offer Class A shares, the disclosure should be corrected in future filings.

You noted that the December 31, 2020 Annual Report for the Large/Mid Cap ETF appears to include a change to the Fund's benchmark. Please explain and in future filings comply with the disclosure requirements for benchmark changes as required under Item 27(b)(2), Instruction 7.

You noted that in the September 30, 2021 Annual Report, the Defensive Strategies Fund and the Growth & Income Fund disclose blended indices as their benchmarks. However, there was no discussion explaining how the indices were chosen or how the blend was achieved. Please include that disclosure in future filings. You further noted that with respect to the Defensive Strategies Fund, the blended index discussions on pages 15 and 31 are not consistent. In future filings, please ensure that all such disclosure comply with the requirements of Item 27(b)(7) of Form N-1A.

You noted that on the December 31, 2020 Annual Report, the performance tables for each ETF compare each Fund's performance to the Index that each Fund tracks. Form N-1A requires that Funds, including ETF's, compare their performance against a recognized broad-based index. Please include appropriate broad based indices in future filings.

You noted that in the December 31, 2020 Annual Report and September 30, 2021 Annual Report, none of the Funds disclose a graphical representation of the Funds' portfolio holdings, as required under Item 27(d)(2) of Form N-1A. You have asked the Trust to ensure that future filings include the required disclosures.

You noted that in the December 31, 2020 Annual Report and September 30, 2021 Annual Report, the following Funds did not include certain required disclosures in their Schedules of Investments as required by Regulation S-X, Article 12-12, Footnote 2, including type of investment, related industry, and country or geographical location;

You noted that each of the ETF's pays a unitary fee to the Adviser. You asked that the Trust confirm in correspondence that the Adviser is current on all obligations owing to other Fund service providers.

You noted that in the Financial Highlights Tables for the Variable Funds, there should be a disclosure stating that the returns do not include any fees or expenses imposed by the contract provider. Please include such disclosure in future filings.

You noted that Note 1 of the December 31, 2020 Annual Report for the Variable Series includes a secondary principal investment objective not mentioned in the prospectus. In future filings, please reconcile this discrepancy.

You noted that in the September 30, 2021 Annual Report, the Related Party Transactions Note did not disclose that the Adviser pays the fees of the sub-advisers. You asked that future filings include that disclosure, along with the fee rates paid to each sub-adviser.

You noted that in the September 30, 2021 Annual Report, page 106 of the report, relating to the International Fund, the investment objective references ADR's, but ADR's are not referenced in the prospectus. You further noted that on August 6, 2021, a prospectus supplement was filed for the Strategic and Conservative Growth Funds. The information in the supplement is inconsistent with the information disclosed in the Annual Report. Lastly, page 107 of the Annual Report does not include ETF's as permissible investments. You asked the Trust to address these inconsistencies in future filings.

You noted that Annual Reports for September 30, 2021 and December 30, 2020 did not include the entirety of the narrative disclosures required under Item 27(d)(1) and Instructions 1(e)(1) of Form N-1A. Please ensure that future filings include all the required disclosures.

You noted that the Annual Report Note discussing renewals of the investment advisory agreements did not fully comply with the requirements of Item 27(d)(6)(i) of Form N-1A. You requested that future filings discussing the investment advisory agreement renewal include sufficient specificity to comply with the above-referenced Item.

You requested that in future Annual Report filings, the table discussing Trustees and Officers include the disclosure that additional information concerning the trustees is available in the SAI.

You noted that the Trust that on Item 4(e)(2) of Form N-CSR, the Trust disclosed 100%. You noted that the Trust should have disclosed 0%. You asked that future filings contain the correct disclosure.

You noted that the September 30, 2021 Annual Report and the December 31, 2020 Annual Report for the Variable Series disclosed the date 11/19/ 2010 in Item 11(a) of Form NCSR. The dates should be 11/19/20 and 11/19/21. You asked that the Trust confirm via correspondence that the dates are correct for all prior years.

You noted that the September 30, 2021 Annual Report and the December 31, 2020 Annual Reports each contain outdated language in response to Item 11(b) of Form N-CSR. You asked that the Trust confirm via correspondence that the Funds were in compliance with this requirement for all years.

You asked that the Trust confirm that all Series and Share Class names for the Variable Series are updated and accurate across all filings, and the SEC web site.

You noted that Item B(10) of Form N-CEN for the September 30, 2021 Funds was checked "No". It appears that a proxy was filed during the period covered. You asked that the Trust confirm that disclosures in compliance with Rule 30(e)(1)(B) will be made.

You noted that Item C(3)(B) of Form N-CEN for the 12/31 ETF's was not checked. You asked the Trust to explain why the Item was not checked.

You asked that the Trust explain why Brinks was not included as a sub-custodian on Item C(12) of Form N-CEN Report for the September 30 Funds.

On pages 113 and 114 of the September 30, 2021 Annual Report, Timothy Partners, Ltd is disclosed as a shareholder servicing agent. You asked that the Trust explain why Timothy Partners, Ltd was not included as a shareholder servicing agent on Item C(13) of Form N-CEN Report for the September 30 Funds.

You noted that in the current prospectus for the Large/Mid Cap Growth Fund, the Small Cap Value Fund, and the Large/Mid Cap Value Funds, there is no disclosure in the Prospectus relating to investments in other affiliated Funds. You further noted that with respect to the High Yield Fund, there was no disclosure in the prospectus relating to mortgage backed securities investing. You asked that the Trust add appropriate disclosures.

You noted that a prospectus supplement was filed on April 17, 2020 changing the name of the Large/Mid Cap Core ETF. You asked that the Trust confirm via correspondence whether any principal strategies or risks change as a result of the name change.

You noted that the current prospectus for the Large/Mid Cap Core ETF contains an incorrect reference to the tracking Index. You asked that the reference be corrected.

You noted that a prospectus supplement dated August 6, 2021 contains incorrect references to the Timothy Plan ETF's. You asked that the prospectus be corrected to reflect the proper names