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EXHIBIT 23
PRICEWATERHOUSECOOPERS PricewaterhouseCoopers LLP
100 East Broad Street
Suite 2100
Columbus, OH 43215-3671
Telephone (614) 225-8700
Facsimile (614) 224-1044
REPORT OF INDEPENDENT ACCOUNTANTS
To the Trustees of One Group Mutual Funds
We have examined management's assertion, included in the accompanying Management
Statement Regarding Compliance with Certain Provisions of the Investment Company
Act of 1940, about the Small Cap Growth Fund, Small Cap Value Fund, Mid Cap
Growth Fund, Mid Cap Value Fund, Diversified Mid Cap Fund, Large Cap Growth
Fund, Large Cap Value Fund, Equity Income Fund, Diversified Equity Fund,
Balanced Fund, Equity Index Fund, Market Expansion Index Fund, International
Equity Index Fund, Diversified International Fund, Government Bond Fund,
Treasury & Agency Fund, Short-Term Bond Fund, Intermediate Bond Fund, Bond Fund,
Income Bond Fund, Treasury Only Money Market Fund, High Yield Bond Fund and
Government Money Market Fund (twenty-three series of One Group Mutual Funds,
hereafter referred to as the "Funds") compliance with the requirements of
subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940
("the Act") as of November 10, 1999, as it relates to the collateral held at
Bank One Trust Company, N.A. in exchange for securities lent on behalf of the
Funds, and about the Bond Fund, Income Bond Fund and Intermediate Bond Fund
(three series of One Group Mutual Funds, hereafter referred to as the "Bond
Funds") compliance with the requirements of subsections (b) and (c) of Rule
17f-2 under the Act as of November 10, 1999, as it relates to the various
securities of the Bond Funds held by Bank One Trust Company, N.A. Management is
responsible for the Funds' and the Bond Funds' compliance with those
requirements. Our responsibility is to express an opinion on management's
assertion about the Funds' and the Bond Funds' compliance based on our
examination.
Our examinations were conducted in accordance with attestation standards
established by the American Institute of Certified Public Accountants and,
accordingly, included examining, on a test basis, evidence about the Funds' and
the Bond 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 November 10, 1999, with
respect to collateral held in exchange for securities lent on behalf of the
Funds and with respect to the various securities of the Bond Funds held by Bank
One Trust Company, N.A.:
- Confirmation, or other procedures as we considered necessary, of all
securities held as collateral in book entry form by the Depository Trust
Company, the Federal Reserve Bank and broker/banks;
- Confirmation, or other procedures as we considered necessary, of all
repurchase agreements and underlying collateral with brokers/banks;
- Confirmation, or other procedures as we considered necessary, of all Master
Note Agreements and Letter of Credit Agreements entered into with
brokers/banks as collateral;
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- Confirmation, or other procedures as we considered necessary, of the
various securities of the Bond Funds held by Bank One Trust Company, N.A.;
- Reconciliation of all such securities held as collateral by Bank One Trust
Company, N.A. in exchange for securities lent on behalf of the Funds and
such securities of the Bond Funds held by Bank One Trust Company, N.A. to
the books and records of the Funds and Bond Funds and Bank One Trust
Company, N.A.
We believe that our examinations provide a reasonable basis for our opinion. Our
examinations do not provide a legal determination on the Funds' and the Bond
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 November 10, 1999, as it relates to the collateral
held in exchange for securities lent on behalf of the Funds, and that the Bond
Funds were in compliance with the requirements of subsections (b) and (c) of
Rule 17f-2 of the Act as of November 10, 1999, as it relates to the various
securities of the Bond Funds held by Bank One Trust Company, N.A., is fairly
stated, in all material respects.
This report is intended solely for the information and use of the Board of
Directors, management, and the Securities and Exchange Commission and is not
intended to be and should not be used by anyone other than these specified
parties.
/s/PricewaterhouseCoopers LLP
February 24, 2000
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MANAGEMENT STATEMENT REGARDING COMPLIANCE WITH CERTAIN PROVISIONS OF THE
INVESTMENT COMPANY ACT OF 1940
We, as members of management of the Small Cap Growth Fund, Small Cap Value Fund,
Mid Cap Growth Fund, Mid Cap Value Fund, Diversified Mid Cap Fund, Large Cap
Growth Fund, Large Cap Value Fund, Equity Income Fund, Diversified Equity Fund,
Balanced Fund, Equity Index Fund, Market Expansion Index Fund, International
Equity Index Fund, Diversified International Fund, Government Bond Fund,
Treasury & Agency Fund, Short-Term Bond Fund, Intermediate Bond Fund, Bond Fund,
Income Bond Fund, Treasury Only Money Market Fund, High Yield Bond Fund and
Government Money Market Fund, (twenty-three series of One Group Mutual Funds,
hereafter referred to as the "Funds"), and the Bond Fund, Income Bond Fund and
Intermediate Bond Fund (three series of One Group Mutual Funds, hereafter
referred to as the "Bond Funds") 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 Funds' and the Bond Funds' compliance with the requirements of
subsections (b) and (c) of Rule 17f-2 as of November 10, 1999.
Based on this evaluation, we assert 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 November 10, 1999, as it relates to the collateral held in
exchange for securities lent on behalf of the Funds, and that the Bond 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 November 10, 1999, as it
relates to the various securities held by Bank One Trust Company, N.A.
One Group Mutual Funds
By: /s/ MARK REDMAN
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Mark Redman, President
One Group Mutual Funds