[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.
9/30/98
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2. State Identification Number
(See attached Exhibit A - State Registration
Report for a list of portfolios and classes)
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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 Drive, 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>
[KPMG PEAT MARWICK LLP LETTERHEAD]
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, 1998. 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, 1998, and with respect to agreement of security
purchases and sales, for the period from June 30, 1998 (the date of our last
examination) through September 30, 1998:
* Confirmation of securities held directly with the transfer agent (DST
Systems, Inc.);
* Confirmation or examination of underlying documentation of 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.
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, 1998, with respect to securities
reflected in the investment account of the Funds is fairly stated, in all
material respects.
<PAGE>
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 and is not intended to be and
should not be used by anyone other than these specified parties.
KPMG Peat Marwick LLP
Minneapolis, Minnesota
November 13, 1998
<PAGE>
AUTOMATED BUSINESS DEVELOPMENT
CLEAR SKY DIVISION
STATE REGISTRATION REPORT AS OF: 10/01/98 @ 12:02:02
GROUP: FAS
<TABLE>
<CAPTION>
FUND NAMES FUND CODE AK AL AR AZ CA CO CT DC DE FL GA GU HI IA ID
<S> <C>
FAS - Income Fund |FAS01 | 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 |
| | | | | | | | | | | | | | | | |
FAS - Growth Fund |FAS03 | 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 |
| | | | | | | | | | | | | | | | |
</TABLE>
[WIDE TABLE CONTINUED FROM ABOVE]
<TABLE>
<CAPTION>
FUND NAMES FUND CODE IL IN KS KY LA MA MD ME MI MN MO MS
<S> <C>
FAS - Income Fund |FAS01 | 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 |
| | | | | | | | | | | | | |
FAS - Growth Fund |FAS03 | 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 |
| | | | | | | | | | | | | |
</TABLE>
PAGE: 1
<PAGE>
AUTOMATED BUSINESS DEVELOPMENT
CLEAR SKY DIVISION
STATE REGISTRATION REPORT AS OF: 10/01/98 @ 12:02:02
GROUP:FAS
<TABLE>
<CAPTION>
FUND NAMES FUND CODE MT NC ND NE NH NJ NM NV NY OH OK OR PA PR
<S> <C>
FAS - Income Fund |FAS01 | 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 |
| | | | | | | | | | | | | | | |
FAS - Growth Fund |FAS03 | 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 |
| | | | | | | | | | | | | | | |
</TABLE>
[WIDE TABLE CONTINUED FROM ABOVE]
<TABLE>
<CAPTION>
FUND NAMES FUND CODE RI SC SD TN TX UT VA VI VT WA WI WV WY
<S> <C>
FAS - Income Fund |FAS01 | 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 |
| | | | | | | | | | | | | | |
FAS - Growth Fund |FAS03 | 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 |
| | | | | | | | | | | | | | |
</TABLE>
PAGE: 2
