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SECURITIES AND EXCHANGE COMMISSION --------------------------
WASHINGTON, D.C. 20549 OMB Approval
FORM N-17f-2 --------------------------
OMB Number: 3235-0360
Certificate of Accounting of Securities and Similar Expires: July 31, 1994
Investment in the Custody of Estimated average burden
Management Investment Companies hours per response... 0.05
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
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1. Investment Company Act File Number: Date examination completed
811-7505 July 28, 2000
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2. State identification Number: N/A
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AL AK AZ AR CA CO
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CT DE DC FL GA HI
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ID IL IN IA KS KY
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LA ME MD MA MI MN
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MS MO MT NE NV NH
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NJ NM NY NC ND OH
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OK OR PA RI SC SD
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TN TX UT VT VA WA
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WV WI WY PUERTO RICO
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Other (specify):
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3. Exact name of investment company as specified in representation statement:
American Independence Funds Trust
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4. Address of principal executive office (number, street, city, state, zip code):
Steven D. Pierce, BISYS Fund Services, 3435 Stelzer Rd, Columbus, Ohio 43219-8001
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AMERICAN INDEPENDENCE FUNDS TRUST
3435 STELZER ROAD
COLUMBUS, OHIO 43219
September 27, 2000
MANAGEMENT STATEMENT REGARDING COMPLIANCE WITH CERTAIN PROVISIONS OF THE
INVESTMENT COMPANY ACT OF 1940
We, as members of management of the American Independence Funds Trust (the
Funds), are responsible for complying with the requirements of subsections (b)
and (c) of Rule 17f-2, "Custody of Investments by Registered Investment
Companies," of the Investment Company Act of 1940. We are also responsible for
establishing and maintaining effective internal controls over compliance with
Rule 17f-2 requirements. We have performed an evaluation of the Funds'
compliance with the requirements of subsections (b) and (c) of Rule 17f-2 as of
July 28, 2000.
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 July 28, 2000 and for the period from May 26, 2000 (date of
the last examination) through July 28, 2000, with respect to securities
reflected in the investment accounts of the Funds.
Sincerely,
/s/ Steven D. Pierce
Steven D. Pierce
Treasurer
American Independence Funds Trust
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To the Board of Trustees of
American Independence Funds Trust
and the
Securities and Exchange Commission:
We have examined management's assertion about American Independence Funds Trust
(the Funds) compliance with the requirements of subsections (b) and (c) of Rule
17f-2 under the Investment Company Act of 1940 (the Act) as of July 28, 2000 and
for the period from May 26, 2000 through July 28, 2000, included in the
accompanying Management Statement Regarding Compliance With Certain Provisions
of the Investment Company Act of 1940. 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 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 Funds' compliance with those
requirements and performing such other procedures as we considered necessary in
the circumstances. Included among our procedures were the following tests
performed as of July 28, 2000 and for the period from May 26, 2000 (the date of
the last examination) through July 28, 2000, with respect to securities
transactions:
1. Confirmation of all securities held as of July 28, 2000 in book entry
form by INTRUST Bank, N.A., without prior notice to management;
2. Verification of all securities purchased/sold but not
received/delivered and securities in transit as of July 28, 2000 via
examination of underlying trade ticket or broker confirmation;
3. Reconciliation of all such securities to the books and records of the
Funds and the INTRUST Bank, N.A.;
4. Confirmation of all repurchase agreements as of July 28, 2000 with
brokers/banks and agreement of underlying collateral with the INTRUST
Bank, N.A. records; and
5. Agreement of fourteen selected security purchases or sales from the
books and records of the Funds to underlying trade tickets or broker
confirmations during the period from May 26, 2000 through July 28,
2000.
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.
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In our opinion, management's assertion that the Funds were in compliance with
the above mentioned provisions of Rule 17f-2 of the Investment Company Act of
1940 as of July 28, 2000 and for the period from May 26, 2000 through July 28,
2000 is fairly stated, in all material respects.
This report is intended solely for the information and use of management 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.
KPMG LLP
Columbus, Ohio
September 27, 2000
