40-17F2

                        REPORT OF INDEPENDENT ACCOUNTANTS

To the Board of Directors of Firstar Stellar Funds

We have examined management's assertion, included in the accompanying Management
Statement Regarding Compliance with Certain Provisions of the Investment Company
Act of 1940, about Firstar Stellar Funds' (the "Company's") compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 under the Investment
Company Act of 1940 ("the Act") as of October 29, 1999. Management is
responsible for the Company's compliance with those requirements. Our
responsibility is to express an opinion on management's assertion about the
Company's compliance based on our examination.

Our examination was conducted in accordance with attestation standards
established by the American Institute of Certified Public Accountants and,
accordingly, included examining, on a test basis, evidence about the Company's
compliance with those requirements and performing such other procedures as we
considered necessary in the circumstances. Included among our procedures were
the following tests performed as of October 29, 1999, and with respect to
agreement of security purchases and sales, for the period from December 1, 1998
through October 29, 1999:

- - Confirmation of securities held by the following institutions in book entry
form: the Federal Reserve Bank of Chicago and the Depository Trust Company;

- - Confirmation of securities and similar investments held by the following
sub-custodian: Bank of New York;

- - Confirmation of securities and similar investments held by outside brokers
and other third parties, except for mutual fund holdings held in nominee name
by Firstar Bank;

- - Reconciliation of such securities to the books and records of the Company and
the custodian;

- - Confirmation of repurchase agreements with brokers and agreement of underlying
collateral with custodian records; and

- - Agreement of 5 security purchases and 5 security sales or maturities since
December 1, 1998 from the books and records of the Company to broker
confirmations.

We believe that our examination provides a reasonable basis for our opinion. Our
examination does not provide a legal determination on the Company's compliance
with specified requirements.

In our opinion, management's assertion that Firstar Stellar Funds was in
compliance with the requirements of subsections (b) and (c) of Rule 17f-2 of the
Investment Company Act of 1940 as of October 29, 1999 with respect to securities
reflected in the investment account of the Company is fairly stated, except for
the exceptions noted, in all material respects.

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

February 11, 2000

EX-99

    MANAGEMENT STATEMENT REGARDING COMPLIANCE WITH CERTAIN PROVISIONS OF THE
                         INVESTMENT COMPANY ACT OF 1940

We, as members of management of Firstar Stellar Funds (the "Company"), are
responsible for complying with the requirements of subsections (b) and (c) of
Rule 17f-2, Custody of Investments by Registered Management Investment
Companies, of the Investment Company Act of 1940. We are also responsible for
establishing and maintaining effective internal controls over compliance with
those requirements. We have performed an evaluation of the Company's compliance
with the requirements of subsections (b) and (c) of Rule 17f-2 as of October 29,
1999, and from November 1, 1998 through October 29, 1999.

Based on this evaluation, we assert that the Company was in compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company
Act of 1940 as of October 29, 1999, and from November 1, 1998 through October
29, 1999, with respect to securities reflected in the investment account of the
Company, except that for a number of option contracts the books of the Company
did not agree to the custodian records. These exceptions were the result of the
untimely removal from the custodian records of options that had either expired
or been sold. In each case the books of the Company were determined to be proper
and the custodian records have been subsequently corrected to reflect the proper
number of option contracts owned.

FIRSTAR STELLAR FUNDS

By:        /s/ Michael T. Karbouski
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           Michael T. Karbouski

           Treasurer
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           Title

           February 11, 2000
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           Date

By:        /s/ Elaine Richards
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           Elaine Richards

           Secretary
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           Title

           February 11, 2000
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           Date