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                               December 29, 2003




Monarch Funds
Two Portland Square
Portland, Maine 04101

Ladies and Gentlemen:

     We have acted as counsel to Monarch  Funds,  a business  trust formed under
the laws of the Commonwealth of Massachusetts (the "Trust"),  in connection with
the filing with the Securities and Exchange Commission ("SEC") of Post-Effective
Amendment No. 35 to the Trust's  Registration  Statement on Form N-1A (File Nos.
33-49570; 811-6742) (the "Post-Effective Amendment"),  registering an indefinite
number shares of beneficial  interest of the Universal,  Institutional  Service,
Preferred and Investor class of the Daily Assets  Government  Fund, Daily Assets
Cash Fund and Daily Assets Treasury Fund; the  Institutional  class of the Daily
Assets  Government  Fund and the Daily Assets Cash Fund, and the Universal class
of the Daily Assets  Government  Obligations  Fund,  each a series of the Trust,
(the "Shares") under the Securities Act of 1933, as amended (the "1933 Act").

     You have  requested  our  opinion  as to the  matters  set  forth  below in
connection  with the filing of the  Post-Effective  Amendment.  For  purposes of
rendering  that opinion,  we have  examined the  Post-Effective  Amendment,  the
Agreement and Declaration of Trust and By-laws of the Trust, and the resolutions
of the Board of  Trustees  of the Trust that  provide  for the  issuance  of the
Shares, and we have made such other investigation as we have deemed appropriate.
In rendering our opinion,  we also have made the assumptions  that are customary
in opinion letters of this kind. We have not verified any of those assumptions.

     Our opinion,  as set forth  herein,  is based on the facts in existence and
the laws in effect on the date hereof and is limited to the federal  laws of the
United States of America and the laws of the Commonwealth of Massachusetts that,
in our  experience,  generally  are  applicable  to the  issuance  of  shares by
entities  such as the Trust.  We express  no opinion  with  respect to any other
laws.

     Based upon and subject to the foregoing, we are of the opinion that:

     1.  The  Shares to  be issued pursuant to the Post-Effective Amendment have
         been duly authorized for issuance by the Trust; and


Kirkpatrick & Lockhart LLP


Monarch Funds
December 29, 2003
Page 2



     2.   When  issued  and  paid  for  upon  the  terms  provided in the  Post-
          Effective Amendment, the Shares to  be  issued  pursuant  to the Post-
          Effective  Amendment  will  be  validly issued,  fully  paid  and non-
          assessable.  In this regard,  however, we  note  that the  Trust  is a
          Massachusetts   business   trust   and,   in  certain   circumstances,
          shareholders  of  a  Massachusetts  business  trust   could  be   held
          personally liable for the obligations of the Trust.

      This  opinion  is rendered  solely in  connection  with the  filing of the
Post-Effective  Amendment and supersedes  any previous  opinions of this firm in
connection with the issuance of Shares.  We hereby consent to the filing of this
opinion with the SEC in connection with the Post-Effective  Amendment and to the
reference to this firm in the statement of additional  information that is being
filed as part of the Post-Effective  Amendment.  In giving our consent we do not
thereby  admit that we are in the category of persons  whose consent is required
under  Section  7 of the  1933  Act or the  rules  and  regulations  of the  SEC
thereunder.

                                                 Very truly yours,

                                                 /s/KIRKPATRICK & LOCKHART LLP

                                                 KIRKPATRICK & LOCKHART LLP