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KPMG LLP
Two Nationwide Plaza
Columbus, OH 43215
To the Board of Directors of
Mercantile Mutual Funds, Inc.
and the
Securities and Exchange Commission:
We have examined management's assertion about the Mercantile Mutual Funds,
Inc.'s (the Funds) compliance with the requirements of subsection (b) and (c) of
Rule 17f-2 under the Investment Company Act of 1940 (the Act) as of April 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 Funds' compliance with those requirements. Our
responsibility is to express an opinion on management's assertion about the
Fund'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 Funds' 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, 1999, and with respect to agreement of security
purchases and sales, for the period from November 30, 1998 (the date of our last
examination) through April 30, 1999:
1. Conformation of all securities held by Mercantile Bank in book entry
form;
2. Verification of all securities purchased/sold but not received/
delivered and securities in transit via examination of underlying trade
ticket or broker confirmation;
3. Reconciliation of all such securities to the books and records of the
Funds and Mercantile Bank;
4. Confirmation of all repurchase agreements with brokers/banks and
agreement of underlying collateral with Mercantile Bank records; and
5. Agreement of twelve selected security purchases, sales or maturities
since our last report from the books and records of the Funds to trade
tickets or broker confirmations.
We believe that our examination provides a reasonable basis for our opinion. Our
examination does not provide a legal determination on the Funds' compliance with
specified requirements.
In our opinion, management's assertion that the Funds were 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, 1999, with respect to securities reflected
in the investment account of the Funds is fairly stated, in all material
respects.
This report is intended solely for the information and use of management of the
Mercantile Mutual Funds, Inc. and the Securities and Exchange Commission and
should not be used for any other purpose.
KPMG LLP
Columbus, Ohio
May 28, 1999
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MERCANTILE MUTUAL FUNDS, INC.
3435 Stelzer Road
Columbus, Ohio 43219
May 28, 1999
MANAGEMENT STATEMENT REGARDING COMPLIANCE WITH CERTAIN PROVISIONS OF THE
INVESTMENT COMPANY ACT OF 1940
We, as members of management of the Mercantile Mutual Funds, Inc. (the Funds),
are responsible for complying with the requirements of subsections (b) and (c)
of Rule 17f-2, "Custody of Investments by Registered Investment Companies," of
the Investment Company Act of 1940. We are also responsible for establishing and
maintaining effective internal controls over compliance with Rule 17f-2
requirements. We have performed an evaluation of the Funds' compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 as of April 30, 1999.
Based on this evaluation, we assert that the Funds were in compliance were 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, 1999 and for the period from
November 30, 1998 through April 30, 1999, with respect to securities reflected
in the investment accounts of the Funds.
Sincerely,
/s/ David Bunstine
David Bunstine
Assistant Secretary
Mercantile Mutual Funds, Inc.
