Exhibit 23I
DAVID JONES & ASSOC., P.C.
LAW FIRM
[GRAPHIC OMITTED] (281) 367-8409 phone
4747 Research Forest Drive (281) 367-8401 facsimile
Suite 180, # 303 [email protected] email
The Woodlands, TX 77381 [email protected] email
January 9, 2001
The Board of Directors
BRASS Funds, Inc., Inc.
14427 Brook Hollow, Suite 336
San Antonio, Texas 78232
Ladies and Gentlemen:
As counsel to BRASS Funds, Inc. (the "Company"), a corporation organized under
the laws of the State of Maryland, I have been asked to render my opinion with
respect to the issuance of an indefinite number of shares of beneficial interest
of the Company (the "Shares") representing proportionate interests in the BRASS
High Yield Tax Exempt Fund (the "Fund"). The Shares of the Fund are a series of
the Company consisting of one class of shares, all as more fully described in
the Prospectus and Statement of Additional Information contained in
pre-effective amendment # 1to Registration Statement on Form N-1A, to which this
opinion is an exhibit, to be filed with the Securities and Exchange Commission.
I have examined the Company's Articles of Incorporation, the Prospectus and
Statement of Additional Information contained in the Registration Statement, and
such other documents, records and certificates as deemed necessary for the
purposes of this opinion.
Based on the foregoing, I am of the opinion that the Shares, when issued,
delivered and paid for in accordance with the terms of the Prospectus and
Statement of Additional Information, will be legally issued, fully paid, and
non-assessable by the Company.
Further, I give my permission to include this opinion as an exhibit to
pre-effective amendment # 1 to the Company's Registration Statement on Form
N-1A.
Very Truly Yours,
David D. Jones
Attorney & Counselor at Law
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