[Adopted in Release No. IC-17085 ( 84,434), effective September 25, 1989,
54 F.R.32048]
U.S. Securities and Exchange Commission
Washington DC 20549
FORM N-17F-2
Form N-17f-2
Certificate of Accounting of Securities and Similar Investments in the Custody
of Management Investment Companies
Pursuant to Rule 17f-2 [17CFR 270.17f-2]
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1. Investment Company Act File Number: 811-07687 Date Examination Complete:
First American Strategy Funds, Inc.
(See attached Exhibit A - State Registration
Report for a list of portfolios and classes) 9/30/97
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2. State Identification Number
See attached Exhibit B for list of states where fund is authorized to
sell and the associated permit number
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3. Exact number of investment company as specified in registration statement:
333-07463
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4. Address of principal executive office: (number, street, city, state, zip
code)
1 Freedom Valley Road, Oaks, PA 19456
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INSTRUCTIONS
This form must be completed by the investment companies that have custody of
securities or similar investments.
Investment Company
<PAGE>
INDEPENDENT AUDITORS' REPORT
The Board of Directors of
First American Strategy Funds Inc.:
We have examined management's assertion, included in its representation letter,
that Income Fund, Growth and Income Fund, Growth Fund, and Aggressive Growth
Fund of First American Strategy Funds, Inc. (the Funds) complied with the
requirements of subsections (b) and (c) of Rule 17f-2 under the Investment
Company Act of 1940 as of September 30, 1997. 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 September 30, 1997, and with respect to agreement of security
purchases and sales, for the period from February 28, 1997 (the date of our last
examination) through September 30, 1997:
* Confirmation of all securities held directly with the transfer agent
(DST Systems, Inc.);
* Confirmation or examination of underlying documentation of all
securities purchased but not received, hypothecated, pledged, placed
in escrow, or out for transfer with broker-dealers and/or transfer
agents;
* Reconciliation of all such securities to the books and records of the
Funds and the Custodian; and
* Test of security transactions since our last report.
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
the specified requirements.
<PAGE>
In our opinion, management's assertion 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 September 30, 1997 with respect to securities
reflected in the investment account of the Funds is fairly stated, in all
material respects.
This report is intended solely for the information and use of management of
First American Strategy Funds, Inc. and the Securities and Exchange Commission
and should not be used for any other purpose.
KPMG Peat Marwick LLP
Minneapolis, Minnesota
November 7, 1997
<PAGE>
EXHBIT A
AUTOMATED BUSINESS DEVELOPMENT
CLEAR SKY DIVISION
STATE REGISTRATION REPORT AS OF: 12/17/97 @ 16:00:07
<TABLE>
<CAPTION>
GROUP: FAS
FUND NAMES FUND CODE AK AL AR AZ CA CO CT DC DE FL GA HI IA ID IL IN KS KY LA MA MD
<S> <C>
FAS - Income Fund |FAS01 | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X |
| | | | | | | | | | | | | | | | | | | | | | |
FAS - Growth and Income Fund |FAS02 | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X |
| | | | | | | | | | | | | | | | | | | | | | |
FAS - Growth Fund |FAS03 | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X |
| | | | | | | | | | | | | | | | | | | | | | |
FAS - Aggressive Growth Fund |FAS04 | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X |
| | | | | | | | | | | | | | | | | | | | | | |
</TABLE>
[WIDE TABLE CONTINUED FROM ABOVE]
<TABLE>
<CAPTION>
<S> <C>
ME MI MN MO MS
X | X | X | X | X |
| | | | |
X | X | X | X | X |
| | | | |
X | X | X | X | X |
| | | | |
X | X | X | X | X |
| | | | |
</TABLE>
<TABLE>
<CAPTION>
GROUP:FAS
FUND NAMES FUND CODE MT NC ND NE NH NJ NM NV NY OH OK OR PA PR RI SC SD TN TX UT VA
<S> <C>
FAS - Income Fund |FAS01 | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X |
| | | | | | | | | | | | | | | | | | | | | | |
FAS - Growth and Income Fund |FAS02 | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X |
| | | | | | | | | | | | | | | | | | | | | | |
FAS - Growth Fund |FAS03 | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X |
| | | | | | | | | | | | | | | | | | | | | | |
FAS - Aggressive Growth Fund |FAS04 | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X | X |
| | | | | | | | | | | | | | | | | | | | | | |
</TABLE>
[WIDE TABLE CONTINUED FROM ABOVE]
<TABLE>
<CAPTION>
VT WA WI WV WY
<S> <C>
X | X | X | X | X |
| | | | |
X | X | X | X | X |
| | | | |
X | X | X | X | X |
| | | | |
X | X | X | X | X |
| | | | |
</TABLE>
<PAGE>
EXHIBIT B - STATE PERMIT REPORT
<TABLE>
<CAPTION>
FUND NAME STATE FILING TYPE FILE NUMBER
<S> <C> <C> <C>
First American Strategy Funds, Inc.
CALIFORNIA A = Annual
COLORADO A = Annual IC 97-11-444
GEORGIA O = Other 56-001597
ILLINOIS A = Annual 9736987
INDIANA A = Annual 96-0417 IC
KENTUCKY A = Annual M32934
LOUISIANA A = Annual 51308
MINNESOTA G = Good Until S R-39117.1
NORTH CAROLINA A = Annual 4657
OHIO O = Other 96126
OKLAHOMA A = Annual I-324896
OREGON A = Annual 96-0718
PENNSYLVANIA A = Annual 96-07-040MF
UTAH A = Annual 5-5885-43
VIRGINIA A = Annual 2411
WYOMING O = Other 20186
FAS - Income Fund
ALASKA O = Other 97-00240
ALABAMA A = Annual
ARKANSAS A = Annual 96-M0692-03
ARIZONA A = Annual S-0051259-QUAL
CONNECTICUT A = Annual SI40323
DELAWARE A = Annual
HAWAII A = Annual
IOWA A = Annual I-36761
IDAHO A = Annual 47139
KANSAS A = Annual 98S0000243
MASSACHUSETTS A = Annual 96-6041-M
MARYLAND A = Annual SM961261
MAINE A = Annual MFR-98-1770
MICHIGAN A = Annual 225976
MISSOURI A = Annual 1996-00692
MISSISSIPPI A = Annual MF-96-07-238
MONTANA A = Annual 35458
NORTH DAKOTA A = Annual R362
NEBRASKA A = Annual 016427
NEW HAMPSHIRE A = Annual
NEW MEXICO A = Annual 975875
NEVADA A = Annual
NEW YORK O = Other S 27 57 86
PUERTO RICO A = Annual S-17263
RHODE ISLAND A = Annual
SOUTH CAROLINA A = Annual MF10124
SOUTH DAKOTA A = Annual 8245
TENNESSEE A = Annual M97-0193
TEXAS G = Good Until S C-50947
VERMONT A = Annual 7/25/96-03
WASHINGTON G = Good Until S C-54080
WISCONSIN A = Annual 318920-03
WEST VIRGINIA G = Good Until S BC-2613
FAS - Growth and Income Fund
ALASKA O = Other 97-00239
ALABAMA A = Annual
ARKANSAS A = Annual 96-M0692-04
ARIZONA A = Annual S-0051257-QUAL
CONNECTICUT A = Annual SI40320
DELAWARE A = Annual
HAWAII A = Annual
IOWA A = Annual I-36762
IDAHO A = Annual 47137
KANSAS A = Annual 98S0000242
MASSACHUSETTS A = Annual 96-6039-M
<PAGE>
EXHIBIT B - STATE PERMIT REPORT
FUND NAME STATE FILING TYPE FILE NUMBER
MARYLAND A = Annual SM961262
MAINE A = Annual MFS-98-1773
MICHIGAN A = Annual 274462
MISSOURI A = Annual 1996-00692
MISSISSIPPI A = Annual MF-96-07-237
MONTANA A = Annual 35456
NORTH DAKOTA A = Annual R360
NEBRASKA A = Annual ------
NEW HAMPSHIRE A = Annual
NEW MEXICO A = Annual 975882
NEVADA A = Annual
NEW YORK O = Other S 27 58 30
PUERTO RICO A = Annual S-17261
RHODE ISLAND A = Annual
SOUTH CAROLINA A = Annual MF10125
SOUTH DAKOTA A = Annual 8246
TENNESSEE A = Annual M97-0193
TEXAS G = Good Until S C-50946
VERMONT A = Annual 7/25/96-4
WASHINGTON G = Good Until S C-54079
WISCONSIN A = Annual 318918-03
WEST VIRGINIA G = Good Until S BC-2614
FAS - Growth Fund
ALASKA O = Other 97-00242
ALABAMA A = Annual
ARKANSAS A = Annual 96-M0692-01
ARIZONA A = Annual S-0051258-QUAL
CONNECTICUT A = Annual SI40321
DELAWARE A = Annual
HAWAII A = Annual
IOWA A = Annual I-36764
IDAHO A = Annual 47138
KANSAS A = Annual 98S0000244
MASSACHUSETTS A = Annual 96-6042-M
MARYLAND A = Annual SM961265
MAINE A = Annual MFR-98-1772
MICHIGAN A = Annual 274461
MISSOURI A = Annual 1996-00692
MISSISSIPPI A = Annual MF-96-07-235
MONTANA A = Annual 35457
NORTH DAKOTA A = Annual R361
NEBRASKA A = Annual ------
NEW HAMPSHIRE A = Annual
NEW MEXICO A = Annual 975866
NEVADA A = Annual
NEW YORK O = Other S 27 57 87
PUERTO RICO A = Annual S-17266
RHODE ISLAND A = Annual
SOUTH CAROLINA A = Annual MF10127
SOUTH DAKOTA A = Annual 8248
TENNESSEE A = Annual M97-0193
TEXAS G = Good Until S C-50945
VERMONT A = Annual 7/25/96-06
WASHINGTON G = Good Until S C-54077
WISCONSIN A = Annual 318919-03
WEST VIRGINIA G = Good Until S BC-2616
FAS - Aggressive Growth Fund
ALASKA O = Other 97-00241
ALABAMA A = Annual
ARKANSAS A = Annual 96-M0692-02
ARIZONA A = Annual S-0051256-QUAL
CONNECTICUT A = Annual SI40322
DELAWARE A = Annual
HAWAII A = Annual
IOWA A = Annual I-36763
<PAGE>
EXHIBIT B - STATE PERMIT REPORT
FUND NAME STATE FILING TYPE FILE NUMBER
IDAHO A = Annual 47136
KANSAS A = Annual 98S0000241
MASSACHUSETTS A = Annual 96-6040-M
MARYLAND A = Annual SM961263
MAINE A = Annual MFR-98-1771
MICHIGAN A = Annual 274460
MISSOURI A = Annual 1996-00692
MISSISSIPPI A = Annual MF-96-07-236
MONTANA A = Annual 35455
NORTH DAKOTA A = Annual R359
NEBRASKA A = Annual -----
NEW HAMPSHIRE A = Annual
NEW MEXICO A = Annual 975867
NEVADA A = Annual
NEW YORK O = Other S 27 57 85
PUERTO RICO A = Annual S-17265
RHODE ISLAND A = Annual
SOUTH CAROLINA A = Annual MF10126
SOUTH DAKOTA A = Annual 8247
TENNESSEE A = Annual M97-0193
TEXAS G = Good Until S C-50944
VERMONT A = Annual 7/25/96-05
WASHINGTON G = Good Until S C-54078
WISCONSIN A = Annual 318917-03
WEST VIRGINIA G = Good Until S BC-2615
</TABLE>