UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-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: 811-09635
Date examination completed: October 31, 2000
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 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:
Valgro Funds, Inc.
4. Address of principal executive office (number, street, city, state, zip
code):
377 Warren Drive, San Francisco, CA 94131-1033
INSTRUCTIONS
This form must be completed by investment companies that have custody of
securities or similar investments.
Investment Company
1. All items must be completed by the investment company.
2. Give this Form to the independent public accountant who, in compliance with
Rule 17f-2 under the Act and applicable state law, examines securities and
similar investments in the custody of the investment company.
Accountant
3. Submit this Form to the Securities and Exchange Commission and appropriate
state securities administrators when filing the certificate of accounting
required by Rule 17f-2 under the Act and applicable state law. File the
original and one copy with the Securities and Exchange Commission's
principal office in Washington, D.C., one copy with the regional office for
the region in which the investment company's principal business operations
are conducted, and one copy with the appropriate state administrator(s), if
applicable.
THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT
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REPORT OF INDEPENDENT CERTIFIED PUBLIC ACCOUNTANTS
Board of Directors
Valgro Funds, Inc.
We have examined management's assertion about Valgro 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 October 31,
2000, included in the accompanying Management Statement Regarding Compliance
with Certain Provisions of the Act. 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 October 31, 2000:
* Confirmation of all securities held by institutions in book entry form at
Brown & Company Securities Corporation; and
* Reconciliation of all such securities 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 that Valgro Funds was in compliance with
the requirements of subsections (b) and (c) of Rule 17f-2 of the Act as of
October 31, 2000, with respect to securities reflected in the investment
account of the Company is fairly stated, in all material respects.
This report is intended solely for the information and use of management of
Valgro Funds and the Securities and Exchange Commission and should not be used
for any other purpose.
Grant Thornton LLP
Chicago, Illinois
*****DATE*****
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Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
We, as members of management of Valgro 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 effective controls over compliance with those
requirements. We have performed an evaluation of the Company's compliance with
the requirements of subsections (b) and (c) of Rule 17f-2 as of October 31,
2000 and from August 31, 2000 through October 31, 2000.
Based on this evaluation, we assert that the Company was in compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company
Act of 1940 as of October 31, 2000 and from August 31, 2000 through October 31,
2000 with respect to securities reflected in the investment account of the
Company.
Valgro Funds, Inc.
By:
Robert Rintel, President
