Form 40-17f-2
(As adopted in Release No. IC-17085, July 26, 1989, effective
September 25, 1989, 54 F.R. 32048.)
U.S. Securities and Exchange Commission
Washington, D.C. 20549
FORM 40-17f-2
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:
811-08763 11/15/99
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(223-545-308) 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:
MH Elite Portfolio of Funds, Inc.
4. Address of principal executive office (number,street,city,state,zip code):
220 Russell Avenue, Rahway, New Jersey 07065
EXHIBIT 1
J. MICHAELS
CERTIFIED PUBLIC ACCOUNTANT
223 MAIN STREET
WOODBRIDGE, NJ 07095
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(732) 634-0148
FAX NO. (732) 855-4961
Report of Independent Accountants
To the Board of Directors of
MH Elite Portfolio of Funds, Inc.
We have examined management's assertion about MH Elite Portfolio of Funds, Inc.
(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 November
15, 1999 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 November 15, 1999, and the period from October 28, 1999
through November 15, 1999 with respect to agreement of purchases and sales
of securities and similiar investments, without prior notice to management.
Reconciliation of confirmation results as to all such securities and similiar
investments to the books and records of the Company and the Custodian.
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 the MH Elite Portfolio of Funds, Inc.
was in compliance with the above mentioned provisions of Rule 17f-2 of the
Investment Company Act of 1940 as of Novemer 15, 1999 is fairly stated, in all
material respects.
This report is intended solely for the information and use of management of
MH Elite Portfolio of Funds, Inc. and Securities and Exchange Commission and
should not be used for any other purpose.
J. Michaels, CPA
Woodbridge, NJ
December 1, 1999
EXHIBIT 2
J. MICHAELS
CERTIFIED PUBLIC ACCOUNTANT
223 MAIN STREET
WOODBRIDGE, NJ 07095
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(732) 634-0148
FAX NO. (732) 855-4961
Mangement Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940
We, as members of management of MH Elite Portfolio of Funds, Inc. (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
evaulation of the Company's compliance with the requirements of subsections
(b) and (c) of Rule 17f-2 as of November 15, 1999.
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
November 15, 1999 wth respect to securities and similiar investments reflected
in the investment account of the Company.
MH Elite Portfolio of Funds, Inc.
By:
Harvey Merson
President
