-----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, PqGj2qfQCQbl7RqBh89EI16glgzhhVLgodwcFLTkEcNWdeshrZXEthcf3m285vq6 eDnesBjf/MdIfvEOLU/H7A== 0000950146-98-000619.txt : 19980416 0000950146-98-000619.hdr.sgml : 19980416 ACCESSION NUMBER: 0000950146-98-000619 CONFORMED SUBMISSION TYPE: 40-17F2 PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 19980415 SROS: NONE FILER: COMPANY DATA: COMPANY CONFORMED NAME: MUTUAL FUND VARIABLE ANNUITY TRUST CENTRAL INDEX KEY: 0000927053 STANDARD INDUSTRIAL CLASSIFICATION: [] STATE OF INCORPORATION: MA FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: 40-17F2 SEC ACT: SEC FILE NUMBER: 811-08630 FILM NUMBER: 98593955 BUSINESS ADDRESS: STREET 1: 101 PARK AVE CITY: NEW YORK STATE: NY ZIP: 10178 BUSINESS PHONE: 2124261600 MAIL ADDRESS: STREET 1: 125 WEST 55TH ST CITY: NEW YORK STATE: NY ZIP: 10019 40-17F2 1 CHASE VISTA FORM 40-17F2 Report of Independent Accountants November 13, 1997 To the Board of Directors of Mutual Fund Variable Annuity Trust We have examined management's assertion about Mutual Fund Variable Annuity Trust's (the "Company") compliance with the requirements of subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 ("the Act") as of August 31, 1997 included in the accompanying Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940. 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 made in accordance with 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 August 31, 1997, and the period from May 31, 1997 (the date of last examination) through August 31, 1997 with respect to agreement of purchases and sales of securities and similar investments: o Count and inspection of domestic securities and similar investments located in the vault of The Chase Manhattan Bank at 4 New York Plaza, 11th Floor, NY, NY; o Testing of securities and similar investments held in book entry form by the Federal Reserve Bank of New York, The Depository Trust Company and the Participants Trust Company via evaluation of the reconciliation procedures used by the Custodian and disposition of any reconciling items related to the Company's positions; o Testing of the reconciliation of securities and similar investments, prepared by management of the Company, between the books and records of the Company and the Custodian; o Liquidation of repurchase agreements and time deposits; o Agreement of corporate actions (eg., stock dividends) due, but not yet received, to the books and records of the Custodian indicating subsequent receipt of the securities at a sub-custodian; o For global securities physically held or held in book entry form by sub-custodians outside of the United States: o Count and inspection of securities and similar investments held in physical form in the countries of England and Malaysia; o Testing of the reconciliation of custody records, prepared by management of the Company, between The Chase Manhattan Bank, Bournemouth, England, the primary custodian outside of the United States, and the corresponding sub-custodians; o Testing of the reconciliation of securities and similar investments from The Chase Manhattan Bank, Bournemouth, England to the records of The Chase Manhattan Bank, New York. 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 Mutual Fund Variable Annuity Trust was in compliance with the above mentioned provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 is fairly stated, in all material respects. This report is intended solely for the information and use of management of Mutual Fund Variable Annuity Trust and Securities and Exchange Commission and should not be used for any other purpose. Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940 -------------------------------------------------------- We, as members of management of Mutual Fund Variable Annuity Trust (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 an effective internal control structure 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 August 31, 1997. Based on this evaluation, we assert that the Company was in compliance with those provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 with respect to securities and similar investments reflected in the investment account of the Company. Mutual Fund Variable Annuity Trust By: /s/ Martin R. Dean - -------------------------------- Martin R. Dean Treasurer Mutual Fund Variable Annuity Trust /s/ Colleen McCoy - -------------------------------- Colleen McCoy Vice President Chase Manhattan Bank Report of Independent Accountants November 13, 1997 To the Trustees of Mutual Fund Trust We have examined management's assertion about Mutual Fund Trust's (the "Company") compliance with the requirements of subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 ("the Act") as of August 31, 1997 included in the accompanying Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940. 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 made in accordance with 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 August 31, 1997, and the period from May 31, 1997 (the date of last examination) through August 31, 1997 with respect to agreement of purchases and sales of securities and similar investments: o Count and inspection of domestic securities and similar investments located in the vault of The Chase Manhattan Bank at 4 New York Plaza, 11th Floor, NY, NY; o Testing of securities and similar investments held in book entry form by the Federal Reserve Bank of New York and The Depository Trust Company via evaluation of the reconciliation procedures used by the Custodian and disposition of any reconciling items related to the Company's positions; o Testing of the reconciliation of securities and similar investments, prepared by management of the Company, between the books and records of the Company and the Custodian; o Confirmation of securities with the transfer agent for investments in other mutual funds; o Liquidation of repurchase agreements, time deposits and securities out for redemption or maturity; o Review of custodian's copies of securities which were out for rollover with brokers and/or transfer agents (both prior to shipment of security and subsequent to receipt of the security with the rollover terms); o Testing of selected purchases and/or sales or maturities of investment securities since our last examination from the books and records of the Company to trade tickets and broker confirmations; o For global securities physically held or held in book entry form by sub-custodians outside of the United States: o Count and inspection of securities and similar investments held in physical form in the countries of England and Malaysia; o Testing of the reconciliation of custody records, prepared by management of the Company, between The Chase Manhattan Bank, Bournemouth, England, the primary custodian outside of the United States, and the corresponding sub-custodians; o Testing of the reconciliation of securities and similar investments from The Chase Manhattan Bank, Bournemouth, England to the records of The Chase Manhattan Bank, New York. In connection with the procedures referred to above for the investment accounts as of August 31, 1997, we were unable to complete the planned procedures with the expected results for the item listed below. For Provident Municipal Fund, 1,259,234 shares were confirmed by the Company's transfer agent as owned by the Company. Security Cusip # Shares/Par -------- ------- ---------- Provident Municipal Fund 625907100 1,253,046 No other matters came to our attention that caused us to believe that the investment accounts as of August 31, 1997 should be adjusted. 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 Mutual Fund Trust was in compliance with the above mentioned provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 is fairly stated, in all material respects. This report is intended solely for the information and use of management of Mutual Fund Trust and Securities and Exchange Commission and should not be used for any other purpose. Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940 -------------------------------------------------------- We, as members of management of Mutual Fund Trust (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 an effective internal control structure 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 August 31, 1997. Based on this evaluation, we assert that the Company was in compliance with those provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 with respect to securities and similar investments reflected in the investment account of the Company. Mutual Fund Trust By: /s/ Martin R. Dean - -------------------------------- Martin R. Dean Treasurer Mutual Fund Trust /s/ Colleen McCoy - -------------------------------- Colleen McCoy Vice President Chase Manhattan Bank Report of Independent Accountants November 13, 1997 To the Board of Directors of Mutual Fund Select Trust We have examined management's assertion about Mutual Fund Select Trust's (the "Company") compliance with the requirements of subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 ("the Act") as of August 31, 1997 included in the accompanying Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940. 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 made in accordance with 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 August 31, 1997, and the period from May 31, 1997 (the date of last examination) through August 31, 1997 with respect to agreement of purchases and sales of securities and similar investments: o Count and inspection of domestic securities and similar investments located in the vault of The Chase Manhattan Bank at 4 New York Plaza, 11th Floor, NY, NY; o Testing of securities and similar investments held in book entry form by The Depository Trust Company via evaluation of the reconciliation procedures used by the Custodian and disposition of any reconciling items related to the Company's positions; o Testing of the reconciliation of securities and similar investments, prepared by management of the Company, between the books and records of the Company and the Custodian; o Confirmation of securities with the transfer agent for investments in other mutual funds; o Testing of selected purchases and/or sales or maturities of investment securities since our last examination from the books and records of the Company to trade tickets and 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 Mutual Fund Select Trust was in compliance with the above mentioned provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 is fairly stated, in all material respects. This report is intended solely for the information and use of management of Mutual Fund Select Trust and Securities and Exchange Commission and should not be used for any other purpose. Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940 -------------------------------------------------------- We, as members of management of Mutual Fund Select Trust (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 an effective internal control structure 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 August 31, 1997. Based on this evaluation, we assert that the Company was in compliance with those provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 with respect to securities and similar investments reflected in the investment account of the Company. Mutual Fund Select Trust By: /s/ Martin R. Dean - -------------------------------- Martin R. Dean Treasurer Mutual Fund Select Trust /s/ Colleen McCoy - -------------------------------- Colleen McCoy Vice President Chase Manhattan Bank Report of Independent Accountants November 13, 1997 To the Board of Directors of Mutual Fund Select Group We have examined management's assertion about Mutual Fund Select Group's (the "Company") compliance with the requirements of subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 ("the Act") as of August 31, 1997 included in the accompanying Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940. 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 made in accordance with 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 August 31, 1997, and the period from May 31, 1997 (the date of last examination) through August 31, 1997 with respect to agreement of purchases and sales of securities and similar investments: o Count and inspection of domestic securities and similar investments located in the vault of The Chase Manhattan Bank at 4 New York Plaza, 11th Floor, NY, NY; o Testing of securities and similar investments held in book entry form by the Federal Reserve Bank of New York, The Depository Trust Company and the Participants Trust Company via evaluation of the reconciliation procedures used by the Custodian and disposition of any reconciling items related to the Company's positions; o Testing of the reconciliation of securities and similar investments, prepared by management of the Company, between the books and records of the Company and the Custodian; o Liquidation of repurchase agreements and time deposits; o Agreement of corporate actions (eg., stock dividends) due, but not yet received, to the books and records of the Custodian indicating subsequent receipt of the securities at a sub-custodian; o Testing of selected purchases and/or sales or maturities of investment securities since our last examination from the books and records of the Company to trade tickets and broker confirmations; o For global securities physically held or held in book entry form by sub-custodians outside of the United States: o Count and inspection of securities and similar investments held in physical form in the countries of England and Malaysia; o Testing of the reconciliation of custody records, prepared by management of the Company, between The Chase Manhattan Bank, Bournemouth, England, the primary custodian outside of the United States, and the corresponding sub-custodians; o Testing of the reconciliation of securities and similar investments from The Chase Manhattan Bank, Bournemouth, England to the records of The Chase Manhattan Bank, New York. 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 Mutual Fund Select Group was in compliance with the above mentioned provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 is fairly stated, in all material respects. However, we were informed by the Custodian that the following position was a fractional share position which was not in the books and records of the Company: Security Cusip Shares -------- ----- ------ Myers Inds Inc 628464109 0.80 This report is intended solely for the information and use of management of Mutual Fund Select Group and Securities and Exchange Commission and should not be used for any other purpose. Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940 -------------------------------------------------------- We, as members of management of Mutual Fund Select Group (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 an effective internal control structure 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 August 31, 1997. Based on this evaluation, we assert that the Company was in compliance with those provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 with respect to securities and similar investments reflected in the investment account of the Company. Mutual Fund Select Group By: /s/ Martin R. Dean - -------------------------------- Martin R. Dean Treasurer Mutual Fund Select Group /s/ Colleen McCoy - -------------------------------- Colleen McCoy Vice President Chase Manhattan Bank Report of Independent Accountants November 13, 1997 To the Board of Directors of Mutual Fund Group We have examined management's assertion about Mutual Fund Group's (the "Company") compliance with the requirements of subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 ("the Act") as of August 31, 1997 included in the accompanying Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940. 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 made in accordance with 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 August 31, 1997, and the period from May 31, 1997 (the date of last examination) through August 31, 1997 with respect to agreement of purchases and sales of securities and similar investments: o Count and inspection of domestic securities and similar investments located in the valut of The Chase Manhattan Bank at 4 New York Plaza, 11th Floor, NY, NY; o Testing of securities and similar investments held in book entry form by the Federal Reserve Bank of New York, The Depository Trust Company and the Participants Trust Company via evaluation of the reconciliation procedures used by the Custodian and disposition of any reconciling items related to the Company's positions; o Testing of the reconciliation of securities and similar investments, prepared by management of the Company, between the books and records of the Company and the Custodian; o Liquidation of repurchase agreements and time deposits; o Agreement of corporate actions (eg., stock dividends) due, but not yet received, to the books and records of the Custodian indicating subsequent receipt of the securities at a sub-custodian; o Testing of selected purchases and/or sales or maturities of investment securities since our last examination from the books and records of the Company to trade tickets and broker confirmations; o For global securities physically held or held in book entry form by sub-custodians outside of the United States: o Count and inspection of securities and similar investments held in physical form in the countries of England and Malaysia; o Testing of the reconciliation of custody records, prepared by management of the Company, between The Chase Manhattan Bank, Bournemouth, England, the primary custodian outside of the United States, and the corresponding sub-custodians; o Testing of the reconciliation of securities and similar investments from The Chase Manhattan Bank, Bournemouth, England to the records of The Chase Manhattan Bank, New York. 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 Mutual Fund Group was in compliance with the above mentioned provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 is fairly stated, in all material respects. This report is intended solely for the information and use of management of Mutual Fund Group and Securities and Exchange Commission and should not be used for any other purpose. Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940 -------------------------------------------------------- We, as members of management of Mutual Fund Group (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 an effective internal control structure 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 August 31, 1997. Based on this evaluation, we assert that the Company was in compliance with those provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 with respect to securities and similar investments reflected in the investment account of the Company. Mutual Fund Group By: /s/ Martin R. Dean - -------------------------------- Martin R. Dean Treasurer Mutual Fund Group /s/ Colleen McCoy - -------------------------------- Colleen McCoy Vice President Chase Manhattan Bank Report of Independent Accountants November 13, 1997 To the Board of Directors of Capital Growth Portfolio We have examined management's assertion about Capital Growth Portfolio's (the "Company") compliance with the requirements of subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 ("the Act") as of August 31, 1997 included in the accompanying Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940. 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 made in accordance with 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 August 31, 1997, and the period from May 31, 1997 (the date of last examination) through August 31, 1997 with respect to agreement of purchases and sales of securities and similar investments: o Testing of securities and similar investments held in book entry form by the Federal Reserve Bank of New York and The Depository Trust Company via evaluation of the reconciliation procedures used by the Custodian and disposition of any reconciling items related to the Company's positions; o Testing of the reconciliation of securities and similar investments, prepared by management of the Company, between the books and records of the Company and the Custodian. o Liquidation of time deposits; 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 Capital Growth Portfolio was in compliance with the above mentioned provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 is fairly stated, in all material respects. However, we were informed by the Custodian that the following position was a fractional share position which was not in the books and records of the Company: Security Cusip Shares -------- ----- ------ Noble Drilling Corp 655042109 0.30 This report is intended solely for the information and use of management of Capital Growth Portfolio and Securities and Exchange Commission and should not be used for any other purpose. Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940 -------------------------------------------------------- We, as members of management of Capital Growth Portfolio (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 an effective internal control structure 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 August 31, 1997. Based on this evaluation, we assert that the Company was in compliance with those provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 with respect to securities and similar investments reflected in the investment account of the Company. Capital Growth Portfolio By: /s/ Martin R. Dean - -------------------------------- Martin R. Dean Treasurer Capital Growth Portfolio /s/ Colleen McCoy - -------------------------------- Colleen McCoy Vice President Chase Manhattan Bank Report of Independent Accountants November 13, 1997 To the Board of Directors of Growth & Income Portfolio We have examined management's assertion about Growth & Income Portfolio's (the "Company") compliance with the requirements of subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 ("the Act") as of August 31, 1997 included in the accompanying Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940. 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 made in accordance with 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 August 31, 1997, and the period from May 31, 1997 (the date of last examination) through August 31, 1997 with respect to agreement of purchases and sales of securities and similar investments: o Testing of securities and similar investments held in book entry form by the Federal Reserve Bank of New York and The Depository Trust Company via evaluation of the reconciliation procedures used by the Custodian and disposition of any reconciling items related to the Company's positions; o Testing of the reconciliation of securities and similar investments, prepared by management of the Company, between the books and records of the Company and the Custodian; o Liquidation of time deposits; o Agreement of corporate actions (eg., stock dividends) due, but not yet received, to the books and records of the Custodian indicating subsequent receipt of the securities at a sub-custodian; In connection with the procedures referred to above, for the investment accounts as of August 31, 1997, we were unable to complete the planned procedures with the expected results for two items listed below. These United States Treasury bills were held at a sub-custodian, and we were unable to obtain confirmation. Security Cusip Par/Amount - -------- ----- ---------- United States Treasury bills 9127945U4 $1,500,000 United States Treasury bills 9127942V5 485,000 No other matters came to our attention that caused us to believe that the investment accounts as of August 31, 1997 should be adjusted. 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 Growth & Income Portfolio was in compliance with the above mentioned provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 is fairly stated, in all material respects. This report is intended solely for the information and use of management of Growth & Income Portfolio and Securities and Exchange Commission and should not be used for any other purpose. Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940 -------------------------------------------------------- We, as members of management of Growth & Income Portfolio (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 an effective internal control structure 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 August 31, 1997. Based on this evaluation, we assert that the Company was in compliance with those provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 with respect to securities and similar investments reflected in the investment account of the Company. Growth & Income Portfolio By: /s/ Martin R. Dean - -------------------------------- Martin R. Dean Treasurer Growth & Income Portfolio /s/ Colleen McCoy - -------------------------------- Colleen McCoy Vice President Chase Manhattan Bank Report of Independent Accountants November 13, 1997 To the Board of Directors of International Equity Portfolio We have examined management's assertion about International Equity Portfolio's (the "Company") compliance with the requirements of subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 ("the Act") as of August 31, 1997 included in the accompanying Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940. 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 made in accordance with 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 August 31, 1997, and the period from May 31, 1997 (the date of last examination) through August 31, 1997 with respect to agreement of purchases and sales of securities and similar investments: o Testing of securities and similar investments held in book entry form by Federal Reserve Bank of New York and The Depository Trust Company via evaluation of the reconciliation procedures used by the Custodian and disposition of any reconciling items related to the Company's positions; o Testing of the reconciliation of securities and similar investments, prepared by management of the Company, between the books and records of the Company and the Custodian; o Liquidation of time deposits; o For global securities physically held or held in book entry form by sub-custodians outside of the United States: o Count and inspection of securities and similar investments held in physical form in the countries of England and Malaysia; o Testing of the reconciliation of custody records, prepared by management of the Company, between The Chase Manhattan Bank, Bournemouth, England, the primary custodian outside of the United States, and the corresponding sub-custodians; o Testing of the reconciliation of securities and similar investments from The Chase Manhattan Bank, Bournemouth, England to the records of The Chase Manhattan Bank, New York. 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 International Equity Portfolio was in compliance with the above mentioned provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 is fairly stated, in all material respects. This report is intended solely for the information and use of management of International Equity Portfolio and Securities and Exchange Commission and should not be used for any other purpose. Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940 -------------------------------------------------------- We, as members of management of International Equity Portfolio (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 an effective internal control structure 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 August 31, 1997. Based on this evaluation, we assert that the Company was in compliance with those provisions of Rule 17f-2 of the Investment Company Act of 1940 as of August 31, 1997 with respect to securities and similar investments reflected in the investment account of the Company. International Equity Portfolio By: /s/ Martin R. Dean - -------------------------------- Martin R. Dean Treasurer International Equity Portfolio /s/ Colleen McCoy - -------------------------------- Colleen McCoy Vice President Chase Manhattan Bank UNITED STATES ---------------------------------- SECURITIES AND EXCHANGE COMMISSION OMB APPROVAL Washington, D.C. 20549 ---------------------------------- OMB Number: 3235-0360 FORM N-17f-2 Expires: July 31, 1994 Estimated average burden hours per response ...0.05 ---------------------------------- 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: 811-8086 August 31, 1997 - ----------------------------------------------------------------------------------------------------------- 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: CAPITAL GROWTH PORTFOLIO - ----------------------------------------------------------------------------------------------------------- 5. Address of principal executive office (number, street, city, state, zip code): George Martinez, Esq., BISYS Fund Services, Inc., 3435 Stelzer Road, Columbus, OH 43219 - -----------------------------------------------------------------------------------------------------------
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) UNITED STATES ---------------------------------- SECURITIES AND EXCHANGE COMMISSION OMB APPROVAL Washington, D.C. 20549 ---------------------------------- OMB Number: 3235-0360 FORM N-17f-2 Expires: July 31, 1994 Estimated average burden hours per response ...0.05 ---------------------------------- 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: 811-8084 August 31, 1997 - -------------------------------------------------------------------------------------------------------- 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: GROWTH & INCOME PORTFOLIO - --------------------------------------------------------------------------------------------------------- 5. Address of principal executive office (number, street, city, state, zip code): George Martinez, Esq., BISYS Fund Services, Inc., 3435 Stelzer Road, Columbus, OH 43219 - ---------------------------------------------------------------------------------------------------------
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) UNITED STATES ---------------------------------- SECURITIES AND EXCHANGE COMMISSION OMB APPROVAL Washington, D.C. 20549 ---------------------------------- OMB Number: 3235-0360 FORM N-17f-2 Expires: July 31, 1994 Estimated average burden hours per response ...0.05 ---------------------------------- 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: 811-7394 August 31, 1997 - -------------------------------------------------------------------------------------------------------------- 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: INTERNATIONAL EQUITY PORTFOLIO - -------------------------------------------------------------------------------------------------------------- 5. Address of principal executive office (number, street, city, state, zip code): George Martinez, Esq., BISYS Fund Services, Inc., 3435 Stelzer Road, Columbus, OH 43219 - --------------------------------------------------------------------------------------------------------------
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) UNITED STATES ---------------------------------- SECURITIES AND EXCHANGE COMMISSION OMB APPROVAL Washington, D.C. 20549 ---------------------------------- OMB Number: 3235-0360 FORM N-17f-2 Expires: July 31, 1994 Estimated average burden hours per response ...0.05 ---------------------------------- 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: 811-5151 August 31, 1997 - ------------------------------------------------------------------------------------------------------------------ 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: MUTUAL FUND GROUP - ------------------------------------------------------------------------------------------------------------------ 5. Address of principal executive office (number, street, city, state, zip code): 101 Park Avenue, New York, New York 10178 - ------------------------------------------------------------------------------------------------------------------
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) UNITED STATES ---------------------------------- SECURITIES AND EXCHANGE COMMISSION OMB APPROVAL Washington, D.C. 20549 ---------------------------------- OMB Number: 3235-0360 FORM N-17f-2 Expires: July 31, 1994 Estimated average burden hours per response ...0.05 ---------------------------------- 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: 811-07843 August 31, 1997 - ------------------------------------------------------------------------------------------------------------- 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: MUTUAL FUND SELECT GROUP - ------------------------------------------------------------------------------------------------------------- 5. Address of principal executive office (number, street, city, state, zip code): 101 Park Avenue, New York, New York 10178 - -------------------------------------------------------------------------------------------------------------
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) UNITED STATES ---------------------------------- SECURITIES AND EXCHANGE COMMISSION OMB APPROVAL Washington, D.C. 20549 ---------------------------------- OMB Number: 3235-0360 FORM N-17f-2 Expires: July 31, 1994 Estimated average burden hours per response ...0.05 ---------------------------------- 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: 811-07841 August 31, 1997 - ------------------------------------------------------------------------------------------------------------------ 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: MUTUAL FUND SELECT TRUST - ------------------------------------------------------------------------------------------------------------------ 5. Address of principal executive office (number, street, city, state, zip code): 101 Park Avenue, New York, New York 10178 - ------------------------------------------------------------------------------------------------------------------
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) UNITED STATES ---------------------------------- SECURITIES AND EXCHANGE COMMISSION OMB APPROVAL Washington, D.C. 20549 ---------------------------------- OMB Number: 3235-0360 FORM N-17f-2 Expires: July 31, 1994 Estimated average burden hours per response ...0.05 ---------------------------------- 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: 811-8358 August 31, 1997 - ------------------------------------------------------------------------------------------------------------------ 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: MUTUAL FUND TRUST - ------------------------------------------------------------------------------------------------------------------ 5. Address of principal executive office (number, street, city, state, zip code): 101 Park Avenue, New York, New York 10178 - ------------------------------------------------------------------------------------------------------------------
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) UNITED STATES ---------------------------------- SECURITIES AND EXCHANGE COMMISSION OMB APPROVAL Washington, D.C. 20549 ---------------------------------- OMB Number: 3235-0360 FORM N-17f-2 Expires: July 31, 1994 Estimated average burden hours per response ...0.05 ---------------------------------- 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: 811-8630 August 31, 1997 - --------------------------------------------------------------------------------------------------------------- 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: MUTUAL FUND VARIABLE ANNUITY TRUST - --------------------------------------------------------------------------------------------------------------- 5. Address of principal executive office (number, street, city, state, zip code): 101 Park Avenue, New York, New York 10178 - ---------------------------------------------------------------------------------------------------------------
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) -----END PRIVACY-ENHANCED MESSAGE-----