-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, LDurTxXlTpU+LQmniwz2sOv/0TrB3c9Jx8tYiTA2mhP9OnS80i7ncdSzwhvIrneO iFf8V4ZLOxzfrF4gaZbwjw== 0001047469-03-006233.txt : 20030220 0001047469-03-006233.hdr.sgml : 20030220 20030220151542 ACCESSION NUMBER: 0001047469-03-006233 CONFORMED SUBMISSION TYPE: 40-17F2 PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20030220 EFFECTIVENESS DATE: 20030220 SUBJECT COMPANY: COMPANY DATA: COMPANY CONFORMED NAME: AMERICAN STRATEGIC INCOME PORTFOLIO INC CENTRAL INDEX KEY: 0000878930 IRS NUMBER: 411705401 STATE OF INCORPORATION: MN FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: 40-17F2 SEC ACT: 1940 Act SEC FILE NUMBER: 811-06404 FILM NUMBER: 03574281 BUSINESS ADDRESS: STREET 1: 222 SOUTH NINTH ST STREET 2: PIPER JAFFRAY TOWER CITY: MINNEAPOLIS STATE: MN ZIP: 55402 BUSINESS PHONE: 6123426000 MAIL ADDRESS: STREET 1: 222 S. 9TH STREET CITY: MINNEAPOLIS STATE: MN ZIP: 55402 FILED BY: COMPANY DATA: COMPANY CONFORMED NAME: AMERICAN STRATEGIC INCOME PORTFOLIO INC CENTRAL INDEX KEY: 0000878930 STANDARD INDUSTRIAL CLASSIFICATION: UNKNOWN SIC - 0000 [0000] IRS NUMBER: 411705401 STATE OF INCORPORATION: MN FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: 40-17F2 BUSINESS ADDRESS: STREET 1: 222 SOUTH NINTH ST STREET 2: PIPER JAFFRAY TOWER CITY: MINNEAPOLIS STATE: MN ZIP: 55402 BUSINESS PHONE: 6123426000 MAIL ADDRESS: STREET 1: 222 S. 9TH STREET CITY: MINNEAPOLIS STATE: MN ZIP: 55402 40-17F2 1 a2103637z40-17f2.txt 40-17F2 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-17f-2 Certificate of Accounting of Securities and Similar Investments in the Custody of Management Investment Companies Pursuant to Rule 17f-2 [17 CFR 270.17F-2]
- ------------------------------------------------------------------------------------------------------------------------------------ 1. Investment Company Act File Number: Date examination completed: 811-6404, 811-6640, 811-7444, 811-7838 July 31, 2001 - ------------------------------------------------------------------------------------------------------------------------------------ 2. State identification Number: ------------------------------------------------------------------------------------------------------------------------------ AL AK AZ AR CA CO ------------------------------------------------------------------------------------------------------------------------------ CT DE DC FL GA HI ------------------------------------------------------------------------------------------------------------------------------ ID IL IN IA KS KY ------------------------------------------------------------------------------------------------------------------------------ LA ME MD MA MI MN ------------------------------------------------------------------------------------------------------------------------------ MS MO MT NE NV NH ------------------------------------------------------------------------------------------------------------------------------ NJ NM NY NC ND OH ------------------------------------------------------------------------------------------------------------------------------ OK OR PA RI SC SD ------------------------------------------------------------------------------------------------------------------------------ TN TX UT VT VA WA ------------------------------------------------------------------------------------------------------------------------------ WV WI WY PUERTO RICO ------------------------------------------------------------------------------------------------------------------------------ Other (specify): N/A - These are closed-end funds and are traded on an exchange ------------------------------------------------------------------------------------------------------------------------------ 3. Exact name of investment company as specified in registration statement: American Strategic Income Portfolio Inc. American Strategic Income Portfolio Inc. II American Strategic Income Portfolio Inc. III American Select Portfolio Inc. - ------------------------------------------------------------------------------------------------------------------------------------ 4. Address of principal executive office (number, street, city, state, zip code): 800 Nicollet Mall Minneapolis, MN 55402 - ------------------------------------------------------------------------------------------------------------------------------------
INSTRUCTIONS This Form must be completed by investment companies that have custody of securities or similar investments. INVESTMENT COMPANY 1. All items must be completed by the investment company. 2. Give this Form to the independent public accountant who, in compliance with Rule 17f-2 under the Act and applicable state law, examines securities and similar investments in the custody of the investment company. ACCOUNTANT 3. Submit this Form to the Securities and Exchange Commission and appropriate state securities administrators when filing the certificate of accounting required by Rule 17f-2 under the Act and applicable state law. File the original and one copy with the Securities and Exchange Commission's principal office in Washington, D.C., one copy with the regional office for the region in which the investment company's principal business operations are conducted, and one copy with the appropriate state administrator(s), if applicable. THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT SEC 2198 (11-91) REPORT OF MANAGEMENT ON COMPLIANCE WITH RULE 17f-2 OF THE INVESTMENT COMPANY ACT OF 1940 October 19, 2001 I, as a member of management of American Strategic Income Portfolio Inc., American Strategic Income Portfolio Inc. II, American Strategic Income Portfolio Inc. III, and American Select Portfolio Inc. (referred to collectively as "the Funds") am 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. I also am responsible for establishing and maintaining effective internal control over compliance with those requirements. We have performed an evaluation of the Funds' compliance with the requirements of subsections (b) and (c) of Rule 17f-2 as of July 31, 2001. Based on this evaluation, I assert that the Funds were in compliance with the requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company Act of 1940 as of November 30, 2000 with respect to securities and similar investments in whole loans reflected in the investment accounts of the Funds, except for the four investments in whole loans for which the underlying documentation was unable to be located at U.S. Bank National Association, the Custodian. /s/ Robert H. Nelson - ------------------------------ Robert H. Nelson Chief Operating Officer U.S. Bancorp Asset Management Report of Independent Accountants To the Board of Directors American Strategic Income Portfolio Inc., American Strategic Income Portfolio Inc. II, American Strategic Income Portfolio Inc. III, and American Select Portfolio Inc. We have examined management's assertion, included in the accompanying "Report of Management on Compliance with Rule 17f-2 of the Investment Company Act of 1940," that the American Strategic Income Portfolio Inc., American Strategic Income Portfolio Inc. II, American Strategic Income Portfolio Inc. III, and American Select Portfolio Inc. (referred to collectively as the Funds) complied with the requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company Act of 1940 (the Act) as of July 31, 2001 with respect to securities and similar investments in whole loans reflected in the investment accounts of the Funds. Management is responsible for the Funds' compliance with those requirements. Our responsibility is to express an opinion on management's assertion 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 Funds' 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 July 31, 2001, and with respect to agreement of security and similar investments, purchases, and sales, for the period from May 31, 2001 (the date of last examination) through July 31, 2001: - - Count and inspection of underlying documentation of securities and similar investments in whole loans designated as being held in the vault of U.S. Bank National Association (the Custodian) in St. Paul, Minnesota, without prior notice to management; - - Review of underlying documentation maintained by the Custodian for securities and similar investments in whole loans in-transit with the respective loan servicer organization: - - Confirmation of all securities and similar investments held by the Federal Reserve Bank of Minneapolis and the Depository Trust Company in book entry form; - - Reconciliation of confirmation results as to all such securities and investments in whole loans to the books and records of the Funds and the Custodian; - - Confirmation of all reverse repurchase agreements with brokers/banks and agreement of underlying collateral with Custodian records; and - - Agreement of ten investment purchases and two investment sales since our last examination from the books and records of the Funds 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 Funds' compliance with specified requirements. In our opinion, management's assertion that the Funds complied with the requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company Act of 1940 as of July 31, 2001, with respect to securities and similar investments in whole loans reflected in the investment accounts of the Funds, is fairly stated, in all material respects, except for specific instances of noncompliance with subsection (b), as discussed below. As discussed in management's assertion, included in the accompanying "Report of Management on Compliance with Rule 17f-2 of the Investment Company Act of 1940," the following noncompliance occurred at the Funds as of July 31, 2001. The underlying documentation for four of the investments in whole loans was unable to be located at the Custodian. However, we were able to review alternative documentation supporting the Funds' original investment in these loans. We also reviewed documents received from the servicers for cash payments received on these four investments in whole loans subsequent to our count date of July 31, 2001. This report is intended solely for the information and use of the board of directors and management of the First American Funds 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/ Ernst & Young LLP October 19, 2001 2
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