Baird, Kurtz & Dobson
City Center Square
1100 Main Street, Suite 2700
Kansas City, MO 64105-2112
816-221-6300 Fax 816-221-6380
www.bkd.com
Independent Accountants
To the Board of Directors of
UMB Scout Tax-Free Money Market Fund, Inc.
and
the Securities and Exchange Commission:
RE: UMB Scout Tax-Free Money Market Fund, Inc.
Form N-17f-2
File Number 811-3556
We have examined management's assertion about UMB SCOUT TAX-FREE
MONEY MARKET FUND, 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, 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 June 30, 1999, with respect to securities
of UMB SCOUT TAX-FREE MONEY MARKET FUND, INC., without prior
notice to management:
Confirmation of all securities held by the Federal Reserve Bank
of Kansas City, The Depository Trust Company, Participants Trust
Company, the Morgan Stanley Trust Company, UMB Bank - N.Y., and
Euroclear in book entry form;
Reconciliation of all such securities to the books and records of
the Company and the Custodian;
Confirmation of all repurchase agreements with brokers/banks and
agreement of underlying collateral with custodian records.
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 UMB SCOUT TAX-FREE
MONEY MARKET FUND, 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, 1999 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 UMB SCOUT TAX-FREE MONEY MARKET FUND, INC. and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
Baird, Kurtz & Dobson
Kansas City, Missouri
September 22, 1999
Member of
Moores
Rowland
International
<PAGE>
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: Date examination
completed:
811-3556 June 30, 1999
2. State Identification Number:
AL *
AK 98 02178
AZ S-0033497-QUAL
AR 87-M0202-01
CA 504-5892
CO IC-91-02-934
CT SI 45573
DE *
DC *
FL *
GA 56-002878
HI *
ID 48846
IL 9841137
IN 85-0448 IC
IA I-19077
KS 86S0000282
KY M29403
LA 59136
ME MF98-6743
MD SM980024
MA 989283
MI 227115
MN R-28108.1
MS MF-98-01-004
MO Q-MT-1298
MT 9202
NE 030301
NV *
NH *
NJ *
NM 685415
NY S 27 53 19
NC *
ND U562
OH 15246
OK SE-321297
OR 98-0080
PA 87-08-115MF
RI *
SC MF11219
SD 10197
TN RM98-3646
TX C-39439
UT B00098969
VT 1/16/98-24
VA 2613
WA C-57893-C
WV MF-24122
WI 341395-03
WY 20515
PUERTO RICO
Other (specify):
*Indicates Fund is registered in state but state does not
issue identification numbers
Securities in the UMB Scout Funds Combined Prospectus
included on one Notice Filing (Balanced Fund, Bond Fund, Capital
Preservation Fund, Kansas Tax-Exempt Bond Fund, Money Market
Fund, Regional Fund, Stock Fund, Stock Select Fund, Tax-Free
Money Market Fund, Worldwide Fund, Worldwide Select Fund)
3. Exact name of investment company as specified in registration
statement:
UMB Scout Tax-Free Money Market Fund, Inc.
4. Address of principal executive office: (number, street, city,
state, zip code)
700 Karnes Boulevard, BMA Tower, Kansas City, Missouri 64108
INSTRUCTIONS
This Form must be completed by the 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
Note: The estimated average burden hours are made solely for
purposes of the Paperwork Reduction Act, and are not derived from
a comprehensive or even a representative survey or study of the
costs of SEC rules and forms. Direct any comments concerning the
accuracy of the estimated average burden hours for compliance
with SEC rules and forms to Kenneth A. Fogash, Deputy Executive
Director, U.S. Securities and Exchange Commission, 450 Fifth
Street, N.W., Washington, D.C. 20549 and Gary Waxman, Clearance
Officer, Office of Management and Budget, Room 3208 New Executive
Office Building, Washington, D.C. 20503.
<PAGE>
Baird, Kurtz & Dobson
City Center Square
1100 Main Street, Suite 2700
Kansas City, MO 64105-2112
816-221-6300 Fax 816-221-6380
www.bkd.com
Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940
We, as members of management of UMB Scout Tax-Free Money Market
Fund, 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 internal
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 June
30, 1999 and from April 30, 1999 through June 30, 1999.
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 June 30,
1999 and from April 30, 1999 through June 30, 1999, with respect
to securities reflected in the investment account of the Company.
UMB SCOUT TAX-FREE MONEY MARKET FUND, INC.
By /s/Laurence J. Schmidt
Laurence J. Schmidt, Senior Vice President
Members of
Moores
Rowland
International
