UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
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]
OMB APPROVAL
OMB Number: 3235-0360
Estimated average burden
hours per response.... 0.05
1. Investment Company Act File Number: Date examination completed:
811- 04246 December 31, 1998
2. State Identification Number:
AL AK AZ AR CA CO
CT DE DC FL X GA HI
ID IL IN IA KS KY
LA ME MD MA MI MN
MS MO MT NE NV NH
NJ NM NY NC ND OH
OK OR PA RI SC SD
TN TX UT VT VA WA
WV WI WY PUERTO RICO
Other (specify):
3. Exact Name of investment company as specified in registration
statement:
C/Funds Group, Inc.
4. Address of principal executive office (number, street, city, state,
zip code):
250 Tampa Avenue West, Venice, FL 34285
INSTRUCTIONS:
This Form must be completed by 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
MANAGEMENT STATEMENT REGARDING COMPLIANCE
WITH CERTAIN PROVISIONS OF
THE INVESTMENT COMPANY ACT OF 1940
We, as members of management of C/FUNDS Group, 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 December 31, 1998 and from December 22,
1998 through December 31, 1998.
Based on this evaluation, we assert that the Company was in
compliance with the requirement of subsections (b) and (c) of
Rule 17f-2 of the Investment Company Act of 1940 as of December
31, 1998 and from December 22, 1998 through December 31, 1998
with respect to securities reflected in the investment account of
the Company.
C/FUNDS Group, Inc.
Roland Caldwell, Jr.
President
Gregory, Sharer & Stuart
100 Second Avenue South, Suite 600
St. Petersburg, Florida 33701-4336
727/821-6161
FAX 727/822-4573
REPORT OF INDEPENDENT
CERTIFIED PUBLIC ACCOUNTANT
To the Board of Directors
C/FUNDS Group, Inc.
We have examined management's assertion about C/FUNDS Group,
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 December 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 December 31, 1998, and with respect to
agreement of security purchases and sales, for the period from
December 22, 1998 through December 31, 1998:
o Confirmation of all securities held by institutions in book
entry form, including the Federal Reserve Bank of Atlanta
and the Depository Trust Company;
o Reconciliation of all such securities to the books and
records of the Company and the Custodian; and
o Agreement of 2 security purchases and 3 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 C/FUNDS Group, 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
December 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 C/FUNDS Group, Inc. and the Securities and Exchange
Commission and should not be used for any other purpose.
GREGORY, SHARER & STUART
St. Petersburg, Florida
April 30, 1999
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
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]
OMB APPROVAL
OMB Number: 3235-0360
Estimated average burden
hours per response.... 0.05
1. Investment Company Act File Number: Date examination completed:
811- 04246 December 22, 1998
2. State Identification Number:
AL AK AZ AR CA CO
CT DE DC FL X GA HI
ID IL IN IA KS KY
LA ME MD MA MI MN
MS MO MT NE NV NH
NJ NM NY NC ND OH
OK OR PA RI SC SD
TN TX UT VT VA WA
WV WI WY PUERTO RICO
Other (specify):
3. Exact Name of investment company as specified in registration
statement:
C/Funds Group, Inc.
4. Address of principal executive office (number, street, city, state,
zip code):
250 Tampa Avenue West, Venice, FL 34285
INSTRUCTIONS:
This Form must be completed by 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
MANAGEMENT STATEMENT REGARDING COMPLIANCE
WITH CERTAIN PROVISIONS OF
THE INVESTMENT COMPANY ACT OF 1940
We, as members of management of C/FUNDS Group, 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 December 22, 1998 and from November 6,
1998 through December 22, 1998.
Based on this evaluation, we assert that the Company was in
compliance with the requirement of subsections (b) and (c) of
Rule 17f-2 of the Investment Company Act of 1940 as of December
22, 1998 and from November 6, 1998 through December 22, 1998 with
respect to securities reflected in the investment account of the
Company.
C/FUNDS Group, Inc.
Roland Caldwell, Jr.
President
Gregory, Sharer & Stuart
100 Second Avenue South, Suite 600
St. Petersburg, Florida 33701-4336
727/821-6161
FAX 727/822-4573
REPORT OF INDEPENDENT
CERTIFIED PUBLIC ACCOUNTANT
To the Board of Directors
C/FUNDS Group, Inc.
We have examined management's assertion about C/FUNDS Group,
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 December 22, 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 December 22, 1998, and with respect to
agreement of security purchases and sales, for the period from
November 6, 1998 through December 22, 1998:
o Confirmation of all securities held by institutions in book
entry form, including the Federal Reserve Bank of Atlanta
and the Depository Trust Company;
o Reconciliation of all such securities to the books and
records of the Company and the Custodian; and
o Agreement of 1 security purchase and 4 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 C/FUNDS Group, 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
December 22, 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 C/FUNDS Group, Inc. and the Securities and Exchange
Commission and should not be used for any other purpose.
GREGORY, SHARER & STUART
St. Petersburg, Florida
April 30, 1999
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
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]
OMB APPROVAL
OMB Number: 3235-0360
Estimated average burden
hours per response.... 0.05
1. Investment Company Act File Number: Date examination completed:
811- 04246 November 6, 1998
2. State Identification Number:
AL AK AZ AR CA CO
CT DE DC FL X GA HI
ID IL IN IA KS KY
LA ME MD MA MI MN
MS MO MT NE NV NH
NJ NM NY NC ND OH
OK OR PA RI SC SD
TN TX UT VT VA WA
WV WI WY PUERTO RICO
Other (specify):
3. Exact Name of investment company as specified in registration
statement:
C/Funds Group, Inc.
4. Address of principal executive office (number, street, city, state,
zip code):
250 Tampa Avenue West, Venice, FL 34285
INSTRUCTIONS:
This Form must be completed by 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
MANAGEMENT STATEMENT REGARDING COMPLIANCE
WITH CERTAIN PROVISIONS OF
THE INVESTMENT COMPANY ACT OF 1940
We, as members of management of C/FUNDS Group, 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 November 6, 1998 and from December 31,
1997 through November 6, 1998.
Based on this evaluation, we assert that the Company was in
compliance with the requirement of subsections (b) and (c) of
Rule 17f-2 of the Investment Company Act of 1940 as of November
6, 1998 and from December 31, 1997 through November 6, 1998 with
respect to securities reflected in the investment account of the
Company.
C/FUNDS Group, Inc.
Roland Caldwell, Jr.
President
Gregory, Sharer & Stuart
100 Second Avenue South, Suite 600
St. Petersburg, Florida 33701-4336
727/821-6161
FAX 727/822-4573
REPORT OF INDEPENDENT
CERTIFIED PUBLIC ACCOUNTANT
To the Board of Directors
C/FUNDS Group, Inc.
We have examined management's assertion about C/FUNDS Group,
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 November 6, 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 November 6, 1998, and with respect to
agreement of security purchases and sales, for the period from
December 31, 1997 through November 6, 1998:
o Confirmation of all securities held by institutions in book
entry form, including the Federal Reserve Bank of Atlanta
and the Depository Trust Company;
o Reconciliation of all such securities to the books and
records of the Company and the Custodian; and
o Agreement of 23 security purchases and 27 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 C/FUNDS Group, 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
November 6, 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 C/FUNDS Group, Inc. and the Securities and Exchange
Commission and should not be used for any other purpose.
GREGORY, SHARER & STUART
St. Petersburg, Florida
February 2, 1999
