ATTACHMENT 77B
Arthur Andersen
REPORT OF INDEPENDENT PUBLIC ACCOUNTANTS
To the Shareholders and Board of Trustees of
the Valenzuela Capital Trust:
In planning and performing our audit of the financial statements
of the Valenzuela Capital Trust for the period ended September 30, 2000,
we considered its 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, not to provide
assurance on internal control.
The management of the Valenzuela Capital Trust 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 generally
accepted accounting principles generally accepted in the United States.
Those controls include the safeguarding of assets against unauthorized
acquisition, use or disposition.
Because of inherent limitations in internal control, error or
fraud may occur and not be detected. Also, projection of any
evaluation of internal control to future periods is subject to the
risk that it may become inadequate because of changes in conditions or
that the effectiveness of the design and operation may deteriorate.
Our consideration of 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 internal control and
its operation, including controls for safeguarding securities, that we
consider to be material weaknesses as defined above as of
September 30, 2000.
This report is intended solely for the information and use of management
and the Board of Trustees of the Valenzuela Capital Trust and the
Securities and Exchange Commission and is not intended to be and should
not be used by anyone other then these specified parties.
Cincinnati, Ohio, /s/Arthur Andersen LLP
October 13, 2000
