JAMES FUNDS
NSAR-B, EX-99, 2000-08-30
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INDEPENDENT AUDITORS' REPORT

To the Trustees and Shareholders of
The James Advantage Funds:

In planning and  performing  our audit of the financial  statements of The James
Advantage  Funds,  including The Golden  Rainbow Fund, The James Small Cap Fund,
The James Market  Neutral Fund and The James Large Cap Plus Fund (the  "Funds"),
for the year ended  June 30,  2000 (on which we have  issued  our  report  dated
August 11, 2000),  we  considered  their  internal  control,  including  control
activities  for  safeguarding  securities,  in order to  determine  our auditing
procedures for the purpose of expressing our opinion on the financial statements
and to comply with the requirements of Form N-SAR, and not to provide  assurance
on the Funds' internal control.

The  management of the Funds is responsible  for  establishing  and  maintaining
internal control. In fulfilling this responsibility,  estimates and judgments by
management  are  required to assess the expected  benefits and related  costs of
controls.  Generally,  controls  that are  relevant  to an audit  pertain to the
entity's objective of preparing financial  statements for external purposes that
are fairly presented in conformity with accounting principles generally accepted
in the United States of America.  Those  controls  include the  safeguarding  of
assets against unauthorized acquisition, use, or disposition.

Because of inherent  limitations in any internal  control,  misstatements due to
error  or  fraud  may  occur  and  not be  detected.  Also,  projections  of any
evaluation  of internal  control to future  periods are subject to the risk that
the internal control may become  inadequate  because of changes in conditions or
that the degree of compliance with policies or procedures may deteriorate.

Our consideration of the Funds' internal control would not necessarily  disclose
all  matters  in  internal  control  that  might be  material  weaknesses  under
standards established by the American Institute of Certified Public Accountants.
A material  weakness is a condition  in which the design or  operation of one or
more of the internal  control  components  does not reduce to a  relatively  low
level the risk that misstatements caused by error or fraud in amounts that would
be material in relation to the financial  statements being audited may occur and
not be detected  within a timely  period by  employees  in the normal  course of
performing their assigned functions.  However, we noted no matters involving the
Funds' internal control and their operation, including controls for safeguarding
securities,  that we consider to be material  weaknesses  as defined above as of
June 30, 2000.

This report is intended solely for the  information  and use of management,  the
Trustees and  Shareholders of The James Advantage  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.



Dayton, Ohio
August 11, 2000



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