0001047469-05-028310.txt : 20111205
0001047469-05-028310.hdr.sgml : 20111205
20051215152802
ACCESSION NUMBER: 0001047469-05-028310
CONFORMED SUBMISSION TYPE: 40-17F2
PUBLIC DOCUMENT COUNT: 1
FILED AS OF DATE: 20051215
DATE AS OF CHANGE: 20051215
EFFECTIVENESS DATE: 20051215
SUBJECT COMPANY:
COMPANY DATA:
COMPANY CONFORMED NAME: AMERICAN STRATEGIC INCOME PORTFOLIO INC II
CENTRAL INDEX KEY: 0000886984
IRS NUMBER: 411719822
STATE OF INCORPORATION: MN
FISCAL YEAR END: 0831
FILING VALUES:
FORM TYPE: 40-17F2
SEC ACT: 1940 Act
SEC FILE NUMBER: 811-06640
FILM NUMBER: 051266489
BUSINESS ADDRESS:
STREET 1: 800 NICOLLET AVE
STREET 2: USBANK
CITY: MINNEAPOLIS
STATE: MN
ZIP: 55402
BUSINESS PHONE: 6123033381
MAIL ADDRESS:
STREET 1: 800 NICOLLET AVE
STREET 2: USBANK
CITY: MINNEAPOLIS
STATE: MN
ZIP: 55402
FILED BY:
COMPANY DATA:
COMPANY CONFORMED NAME: AMERICAN STRATEGIC INCOME PORTFOLIO INC II
CENTRAL INDEX KEY: 0000886984
STANDARD INDUSTRIAL CLASSIFICATION: UNKNOWN SIC - 0000 [0000]
IRS NUMBER: 411719822
STATE OF INCORPORATION: MN
FISCAL YEAR END: 0831
FILING VALUES:
FORM TYPE: 40-17F2
BUSINESS ADDRESS:
STREET 1: 800 NICOLLET AVE
STREET 2: USBANK
CITY: MINNEAPOLIS
STATE: MN
ZIP: 55402
BUSINESS PHONE: 6123033381
MAIL ADDRESS:
STREET 1: 800 NICOLLET AVE
STREET 2: USBANK
CITY: MINNEAPOLIS
STATE: MN
ZIP: 55402
40-17F2
1
a2166040z40-17f2.txt
40-17F2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
--------------------------
OMB APPROVAL
--------------------------
FORM N-17f-2 OMB Number: 3235-0360
Expires: July 31, 2006
Certificate of Accounting of Securities Estimated average burden
and Similar Investments in the Custody of hours per response.....1.0
Management Investment Companies --------------------------
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
--------------------------------------------------------------------------------------------------------------
1. Investment Company Act File Number: Date examination completed:
811-03313, 811-07687, 811-07680, 811-21193, 811-07678, 811-06404, 811-06640 August 31, 2005
811-07444, 811-07838, 811-05642
--------------------------------------------------------------------------------------------------------------
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):
--------------------------------------------------------------------------------------------------------------
3. Exact name of investment company as specified in registration statement:
First American Strategy Funds, Inc., First American Funds, Inc., American Strategic Income Portfolio Inc.,
American Strategic Income Portfolio, Inc. II, American Strategic Income Portfolio Inc. III, American Select
Portfolio Inc., American Income Fund, Inc., American Municipal Income Portfolio Inc., First American
Minnesota Municipal Income Fund II, Inc., Minnesota Municipal Income 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
SEC2198 (10-03)
SEC's COLLECTION OF INFORMATION
An agency may not conduct or sponsor, and a person is not required to respond
to, a collection of information unless it displays a currently valid OMB control
number. Filing of Form N-17f-2 is mandatory for an investment company that has
custody of securities or similar investments. Rule 17f-2 under section 17(f) of
the Investment Company Act of 1940 requires the investment company to retain an
independent public accountant to verify the company's securities and similar
investments by actual examination three times during each fiscal year. The
accountant must prepare a certificate stating that the examination has occurred
and describing the examination, and must transmit the certificate to the
Commission with Form N-17f-2 as a cover sheet. The Commission uses the Form to
ensure that the certificate is properly attributed to the investment company.
The Commission estimates that the burden of completing Form N-17f-2 is
approximately 1.0 hours per filing. Any member of the public may direct to the
Commission any comments concerning the accuracy of the burden estimate of this
Form, and any suggestions for reducing this burden. This collection of
information has been reviewed by the Office of Management and Budget in
accordance with the clearance requirements of 44 U.S.C. Section 3507. Responses
to this collection of information will not be kept confidential.
2
Report of Independent Registered Public Accounting Firm
The Board of Directors
First American Funds, Inc.
We have examined management's assertion, included in the accompanying Management
Statement Regarding Compliance With Certain Provisions of the Investment Company
Act of 1940 (the Act), that the Government Obligations Fund, Prime Obligations
Fund, Tax Free Obligations Fund, Treasury Obligations Fund, and U.S. Treasury
Money Market Fund of the First American Funds, Inc. (referred to collectively as
the Funds) complied with the requirements of subsections (b) and (c) of Rule
17f-2 of the Act as of August 31, 2005. Management is responsible for the Funds'
compliance with those requirements. Our responsibility is to express an opinion
on management's assertion about the Funds' compliance based on our examination.
Our examination was conducted in accordance with the standards of the Public
Company Accounting Oversight Board (United States) 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 August 31, 2005, and, with respect to agreement of security
purchases and sales, for the period from May 31, 2005 through August 31, 2005:
- Confirmation of all securities held by institutions in book entry form
(Bank of New York, Depository Trust Company, and Federal Reserve Bank of
Boston)
- Confirmation of all securities hypothecated, pledged, placed in escrow, or
out for transfer with brokers, pledges, or transfer agents
- Reconciliation of all such securities to the books and records of the
Funds and U.S. Bank National Association (the Custodian)
- Confirmation of all repurchase agreements with brokers/banks and agreement
of underlying collateral with the Custodian's records
- Agreement of seven security purchases and seven security sales or
maturities 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 Act as of August
31, 2005, with respect to securities reflected in the investment accounts of the
Funds, is fairly stated in all material respects.
This report is intended solely for the information and use of management and the
Board of Directors of the 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
Minneapolis, Minnesota
October 14, 2005
2
Management Statement Regarding Compliance With Certain Provisions of the
Investment Company Act of 1940
October 14, 2005
We, as members of management of the Government Obligations Fund, Prime
Obligations Fund, Tax Free Obligations Fund, Treasury Obligations Fund, and US
Treasury Money Market Fund of the First American Funds, Inc. (referred to
collectively as the Funds), 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 (the
Act). We are also responsible for establishing and maintaining effective
internal controls 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 August 31, 2005, and from May 31, 2005 through August
31, 2005.
Based on this evaluation, we 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 August 31, 2005, and from May 31, 2005 through August 31, 2005
with respect to securities reflected in the investment accounts of the Funds.
By: /s/ Thomas S. Schreier, Jr.
--------------------------------
Thomas S. Schreier, Jr.
President
By: /s/ Charles D. Gariboldi, Jr.
--------------------------------
Charles D. Gariboldi, Jr.
Treasurer
Report of Independent Registered Public Accounting Firm
The Board of Directors
American Income Fund, Inc.
American Municipal Income Portfolio Inc.
First American Minnesota Municipal Income Fund II, Inc.
Minnesota Municipal Income Portfolio Inc.
We have examined management's assertion, included in the accompanying Management
Statement Regarding Compliance With Certain Provisions of the Investment Company
Act of 1940 (the Act), that the American Income Fund, Inc., American Municipal
Income Portfolio Inc., First American Minnesota Municipal Income Fund II, Inc.,
and Minnesota Municipal Income Portfolio Inc. (referred to collectively as the
Funds) complied with the requirements of subsections (b) and (c) of Rule 17f-2
under the Act as of August 31, 2005. Management is responsible for the Funds'
compliance with those requirements. Our responsibility is to express an opinion
on management's assertion about the Funds' compliance based on our examination.
Our examination was conducted in accordance with the standards of the Public
Company Accounting Oversight Board (United States) 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 August 31, 2005, and, with respect to agreement of security
purchases and sales, for the period from May 31, 2005 through August 31, 2005:
- Count and inspection of all securities located in the vault of U.S. Bank
National Association (the Custodian) in Milwaukee, Wisconsin
- Confirmation of all securities held by institutions in book entry form
(Bank of New York, Depository Trust Company, and Federal Reserve Bank of
Boston)
- Confirmation of all securities hypothecated, pledged, placed in escrow, or
out for transfer with brokers, pledges, or transfer agents
- Reconciliation of all such securities to the books and records of the
Funds and the Custodian
- Agreement of four security purchases and four security sales or maturities
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 Act as of August
31, 2005, with respect to securities reflected in the investment accounts of the
Funds, is fairly stated in all material respects.
This report is intended solely for the information and use of management and the
Board of Directors of the 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
Minneapolis, Minnesota
October 14, 2005
2
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
October 14, 2005
We, as members of management of the American Income Fund, Inc., American
Municipal Income Portfolio Inc., First American Minnesota Municipal Income Fund
II, Inc., and Minnesota Municipal Income Portfolio Inc. (referred to
collectively as the Funds), 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
Funds' compliance with the requirements of subsections (b) and (c) of Rule
17f-2 as of August 31, 2005, and from May 31, 2005 through August 31, 2005.
Based on this evaluation, we 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 August 31, 2005, and from May 31, 2005 through August 31,
2005, with respect to securities reflected in the investment accounts of the
Funds.
By: /s/ Thomas S. Schreier, Jr.
--------------------------------
Thomas S. Schreier, Jr.
President
By: /s/ Charles D. Gariboldi, Jr.
--------------------------------
Charles D. Gariboldi, Jr.
Treasurer
Report of Independent Registered Public Accounting Firm
The Board of Directors
First American Strategy Funds, Inc.
We have examined management's assertion, included in the accompanying Management
Statement Regarding Compliance With Certain Provisions of the Investment Company
Act of 1940 (the Act), that the Aggressive Allocation Fund, Growth & Income
Allocation Fund, Growth Allocation Fund, and Income Allocation Fund of the First
American Strategy Funds, Inc. (referred to collectively as the Funds) complied
with the requirements of subsections (b) and (c) of Rule 17f-2 of the Act as of
August 31, 2005. Management is responsible for the Funds' compliance with those
requirements. Our responsibility is to express an opinion on management's
assertion about the Funds' compliance based on our examination.
Our examination was conducted in accordance with the standards of the Public
Company Accounting Oversight Board (United States) 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 August 31, 2005, and, with respect to agreement of security
purchases and sales, for the period from May 31, 2005 through August 31, 2005:
- Confirmation of all securities held by institutions in book entry form
(Bank of New York, Depository Trust Company, and Federal Reserve Bank of
Boston)
- Confirmation of all securities hypothecated, pledged, placed in escrow, or
out for transfer with brokers, pledges, or transfer agents
- Reconciliation of all such securities and investments to the books and
records of the Funds and U.S. Bank National Association (the Custodian)
- Agreement of four security purchases and five security sales or maturity
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 Act as of August
31, 2005, with respect to securities reflected in the investment accounts of the
Funds, is fairly stated in all material respects.
This report is intended solely for the information and use of management and the
Board of Directors of the 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
Minneapolis, Minnesota
October 14, 2005
2
Management Statement Regarding Compliance With Certain Provisions of the
Investment Company Act of 1940
October 14, 2005
We, as members of management of the Aggressive Allocation Fund, Growth & Income
Allocation Fund, Growth Allocation Fund, and Income Allocation Fund of the First
American Strategy Funds, Inc. (referred to collectively as the Funds), 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 Funds' compliance
with the requirements of subsections (b) and (c) of Rule 17f-2 as of August 31,
2005, and from May 31, 2005 through August 31, 2005.
Based on this evaluation, we 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 August 31, 2005, and from May 31, 2005 through August 31,
2005, with respect to securities reflected in the investment accounts of the
Funds.
By: /s/ Thomas S. Schreier, Jr.
--------------------------------
Thomas S. Schreier, Jr.
President
By: /s/ Charles D. Gariboldi, Jr.
--------------------------------
Charles D. Gariboldi, Jr.
Treasurer
Report of Independent Registered Public Accounting Firm
The Board of Directors
American Strategic Income Portfolio Inc.
American Strategic Income Portfolio Inc. II
American Strategic Income Portfolio Inc. III
American Select Portfolio Inc.
We have examined management's assertion, included in the accompanying Management
Statement Regarding Compliance With Certain Provisions of the Investment Company
Act of 1940 (the Act), that 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
Act as of August 31, 2005. Management is responsible for the Funds' compliance
with those requirements. Our responsibility is to express an opinion on
management's assertion about the Funds' compliance based on our examination.
Our examination was conducted in accordance with the standards of the Public
Company Accounting Oversight Board (United States) 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 August 31, 2005, and, with respect to agreement of security
purchases and sales, for the period from May 31, 2005 (the date of our last
examination) through August 31, 2005:
- Count and inspection of all securities located in the vault of U.S. Bank
National Association (the Custodian) in Milwaukee, Wisconsin
- Count and inspection of underlying documentation of securities in whole
loans designated as being held in the vault of the Custodian in St. Paul,
Minnesota
- Review of underlying documentation maintained by the Custodian for
securities in whole loans in transit with the respective loan servicer
organization
- Confirmation of all securities held by institutions in book entry form
(Bank of New York, Depository Trust Company, and Federal Reserve Bank of
Boston)
- Reconciliation of confirmation results as to all such securities 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
- Agreement of four security purchases and four security 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 Act as of August
31, 2005, with respect to securities reflected in the investment accounts of the
Funds, is fairly stated in all material respects.
This report is intended solely for the information and use of management and the
Board of Directors of the 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
Minneapolis, Minnesota
October 14, 2005
2
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
October 14, 2005
We, as members of management of 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), 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
Funds' compliance with the requirements of subsections (b) and (c) of Rule 17f-2
as of August 31, 2005, and from May 31, 2005 through August 31, 2005.
Based on this evaluation, we 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 August 31, 2005, and from May 31, 2005 to August 31, 2005,
with respect to securities reflected in the investment accounts of the Funds.
By: /s/ Thomas S. Schreier, Jr.
--------------------------------
Thomas S. Schreier, Jr.
President
By: /s/ Charles D. Gariboldi, Jr.
--------------------------------
Charles D. Gariboldi, Jr.
Treasurer