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SECURITIES AND EXCHANGE COMMISSION --------------------------
WASHINGTON, D.C. 20549 OMB Approval
FORM N-17f-2 --------------------------
OMB Number: 3235-0360
Certificate of Accounting of Securities and Similar Expires: July 31, 1994
Investment in the Custody of Estimated average burden
Management Investment Companies hours per response... 0.05
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
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1. Investment Company Act File Number: Date examination completed
811-2378 7/17/98
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2. State identification Number: N/A
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AL AK AZ AR CA CO
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CT DE DC FL GA HI
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ID IL IN IA KS KY
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LA ME MD MA MI MN
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MS MO MT NE NV NH
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NJ NM NY NC ND OH
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OK OR PA RI SC SD
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TN TX UT VT VA WA
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WV WI WY PUERTO RICO
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Other (specify):
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3. Exact name of investment company as specified in representation statement:
Circle Income Shares, Inc.
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4. Address of principal executive office (number, street, city, state, zip code):
111 Monument Circle 17th Floor
Indianapolis, IN 46204
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REPORT OF INDEPENDENT PUBLIC ACCOUNTANTS
To the Board of Directors of
Circle Income Shares, Inc.:
We have examined management's assertion about Circle Income Shares, Inc.'s (the
"Company's") compliance with the requirements of subsections (b) and (c) of Rule
17f-2 under the Investment Company Act of 1940 ("the Act") as of March 31, 1998,
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 March 31, 1998, and with respect to agreement of security
purchases and sales, for the period from July 1, 1997 through March 31, 1998:
o Confirmation of all securities held by institutions in book
entry form (Federal Reserve Bank of Cleveland, The Depository
Trust Company, Participants Trust Company);
o Reconciliation of all such securities to the books and records
of the Company and the Custodian;
o Agreement of three security purchases and three security sales
or maturities since our last report from the books and records
of the Company to broker confirmations.
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 Circle Income Shares, Inc. was in
compliance with the requirements of subsections (b) and (c) of Rule 17f-2 of the
Investment Company Act of 1940 as of March 31, 1998 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
Circle Income Shares, Inc. and the Securities and Exchange Commission and should
not be used for any other purpose.
ARTHUR ANDERSEN LLP
Indianapolis, Indiana,
May 29, 1998.
<PAGE> 3
REPORT OF INDEPENDENT PUBLIC ACCOUNTANTS
To the Board of Directors of
Circle Income Shares, Inc.:
We have examined management's assertion about Circle Income Shares, Inc.'s (the
"Company's") compliance with the requirements of subsections (b) and (c) of Rule
17f-2 under the Investment Company Act of 1940 ("the Act") as of April 30, 1998,
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 April 30, 1998, and with respect to agreement of security
purchases and sales, for the period from April 1, 1997 through April 30, 1998:
o Confirmation of all securities held by institutions in book
entry form (Federal Reserve Bank of Cleveland, The Depository
Trust Company, Participants Trust Company);
o Reconciliation of all such securities to the books and records
of the Company and the Custodian;
o Agreement of one security purchase and one security sale or
maturity since our last report from the books and records of
the Company to broker confirmations.
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 Circle Income Shares, Inc. was in
compliance with the requirements of subsections (b) and (c) of Rule 17f-2 of the
Investment Company Act of 1940 as of April 30, 1998 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
Circle Income Shares, Inc. and the Securities and Exchange Commission and should
not be used for any other purpose.
ARTHUR ANDERSEN LLP
Indianapolis, Indiana,
June 22, 1998.
<PAGE> 4
REPORT OF INDEPENDENT PUBLIC ACCOUNTANTS
To the Board of Directors of
Circle Income Shares, Inc.:
We have examined management's assertion about Circle Income Shares, Inc.'s (the
"Company's") compliance with the requirements of subsections (b) and (c) of Rule
17f-2 under the Investment Company Act of 1940 ("the Act") as of June 30, 1998,
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 June 30, 1998, and with respect to agreement of security
purchases and sales, for the period from May 1, 1997 through June 30, 1998:
o Confirmation of all securities held by institutions in book
entry form (Federal Reserve Bank of Cleveland, The Depository
Trust Company, Participants Trust Company);
o Reconciliation of all such securities to the books and records
of the Company and the Custodian;
o Agreement of one security purchase and one security sale or
maturity since our last report from the books and records of
the Company to broker confirmations.
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 Circle Income Shares, Inc. was in
compliance with the requirements of subsections (b) and (c) of Rule 17f-2 of the
Investment Company Act of 1940 as of June 30, 1998 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
Circle Income Shares, Inc. and the Securities and Exchange Commission and should
not be used for any other purpose.
ARTHUR ANDERSEN LLP
Indianapolis, Indiana,
July 17, 1998.
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REPORT OF INDEPENDENT PUBLIC ACCOUNTANTS
Board of Directors of
Circle Income Shares, Inc.:
In planning and performing our audit of the financial statements of Circle
Income Shares, Inc. for the year ended June 30, 1998, we considered its internal
control, including controls over 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 Circle Income Shares, Inc. 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. Those controls include the safeguarding of assets against
unauthorized acquisition, use or disposition.
Because of inherent limitations in internal control, errors or irregularities
may occur and may 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 any
specific internal control component does not reduce to a relatively low level
the risk that errors or irregularities 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,
including controls over safeguarding securities, that we consider to be material
weaknesses as defined above as of June 30, 1998.
This report is intended solely for the information and use of management of
Circle Income Shares, Inc. and the Securities and Exchange Commission and should
not be used for any other purpose.
ARTHUR ANDERSEN LLP
Indianapolis, Indiana,
July 17, 1998.
