Neiman Large Cap Value Fund

0001413042-22-000536.txt : 20220608 0001413042-22-000536.hdr.sgml : 20220608 20220608111637 ACCESSION NUMBER: 0001413042-22-000536 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 2 CONFORMED PERIOD OF REPORT: 20220331 FILED AS OF DATE: 20220608 DATE AS OF CHANGE: 20220608 EFFECTIVENESS DATE: 20220608 FILER: COMPANY DATA: COMPANY CONFORMED NAME: NEIMAN FUNDS CENTRAL INDEX KEY: 0001215880 IRS NUMBER: 562328324 FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: N-CEN SEC ACT: 1940 Act SEC FILE NUMBER: 811-21290 FILM NUMBER: 221002885 BUSINESS ADDRESS: STREET 1: 305 SPINDRIFT DRIVE CITY: WILLIAMSVILLE STATE: NY ZIP: 14221 BUSINESS PHONE: 8583360832 MAIL ADDRESS: STREET 1: 305 SPINDRIFT DRIVE CITY: WILLIAMSVILLE STATE: NY ZIP: 14221

0001215880 S000005312 Neiman Large Cap Value Fund

C000014503 No-Load Shares NEIMX

C000117003 Class A Shares NEAMX

N-CEN 1 primary_doc.xml X0404 N-CEN LIVE 0001215880 XXXXXXXX N-1A S000005312 C000014503 C000117003 NEIMAN FUNDS 811-21290 0001215880 549300RIX1W2VYXCFZ85 305 SPINDRIFT DRIVE WILLIAMSVILLE 14221 US-NY US 7166331515 NEIMAN FUNDS 305 SPINDRIFT DRIVE WILLIAMSVILLE 14221 7166331515 All accounts, books and documents required to be maintained by the Registrant pursuant to Section 31(a) of the Investment Company Act of 1940 and Rules 31a-1 through 31a-3 thereunder are maintained at the office of the Registrant except all those relating to the activities of the Funds' Custodian, Transfer Agent and Shareholder Servicing Agent. Mutual Shareholder Services, LLC 8000 Town Centre Drive, Suite 400 Broadview Heights 44147 4409220066 All accounts, books and documents required to be maintained by the Transfer Agent, Fund Accounting Agent and Shareholder Servicing Agent pursuant to Section 31(a) of the Investment Company Act of 1940 and Rules 31a-1 through 31a-3. US Bank, N.A. 425 Walnut Street Cincinnati 45202 5136324140 All accounts, books and documents required to be maintained by the Custodian. N N N N-1A 4 Y MICHAEL LOMAS 002672193 Y DARLA CALRK N/A N SUZANNE COWAN DIMEFF 004420595 N DANIEL NEIMAN 004649480 305 SPINDRIFT DRIVE WILLIAMSVILLE 14221 XXXXXX N N N N N N N ARBOR COURT CAPITAL, LLC 008-67609 000143839 N/A N N COHEN & COMPANY, LTD. 925 N/A N N N N N N N Neiman Large Cap Value Fund S000005312 549300VJZMKII44H9B06 Y 2 0 0 N/A N N Y N N/A N/A N/A Rule 32a-4 (17 CFR 270.32a-4) Y Y N N NEIMAN FUNDS MANAGEMENT LLC 801-70650 000151749 N/A N MUTUAL SHAREHOLDER SERVICES, LLC 084-05821 549300TSNG2XMCUGTB05 N N N FIS N/A N N US BANK, N.A. 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N MUTUAL SHAREHOLDER SERVICES, LLC 549300TSNG2XMCUGTB05 N N N PREMIER FUND SOLUTIONS, INC. N/A N N N PERSHING LLC 008-17574 000007560 ZI8Q1A8EI8LQFJNM0D94 18 MERRILL LYNCH PROFESSIONAL CLEARING CORP. 008-33359 000016139 549300PMHS66E71I2D34 1448 KNIGHT DIRECT LLC 008-66957 000135924 N/A 18 STONEX FINANCIAL INC. 008-51269 000045993 984500ACC474K53F8E17 1800 PRECISION SECURITIES, LLC 008-52441 000103976 635400GBP4QTL7NATT68 1310 4594 0 N 31042495 N N N N false false true false false false INTERNAL CONTROL RPT 2 ncenneiman.htm Neiman Large Cap Value Fund

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Shareholders of Neiman Large Cap Value Fund and

Board of Trustees of Neiman Funds

In planning and performing our audit of the financial statements of Neiman Large Cap Value Fund (the “Fund”), a series of Neiman Funds, as of and for the year ended March 31, 2022, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Fund’s internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Fund’s internal control over financial reporting. Accordingly, we express no such opinion.

The management of the Fund is responsible for establishing and maintaining effective internal control over financial reporting. In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls. A fund’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles (GAAP). A fund’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the fund; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the fund are being made only in accordance with authorizations of management and trustees of the fund; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a fund’s assets that could have a material effect on the financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the Fund’s annual or interim financial statements will not be prevented or detected on a timely basis.

Our consideration of the Fund’s internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the PCAOB. However, we noted no deficiencies in the Fund’s internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness as defined above as of March 31, 2022.

This report is intended solely for the information and use of management and the Board of Trustees of the Fund and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.

/s/Cohen & Company, Ltd.

COHEN & COMPANY, LTD.

Milwaukee, Wisconsin

May 26, 2022