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]
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1. Investment Company Act File Number: Date examination completed:
811- 04246 April 19, 2000
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
C/Funds Group, Inc.
P. O. Box 622
Venice, FL 34284-0622
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 April 19,2000 and from January 1, 2000
through April 19, 2000.
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 April 19,
2000 and from January 1, 2000 through April 19, 2000 with respect
to securities reflected in the investment account of the Company.
C/FUNDS Group, Inc.
Roland G. 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 ACCOUNTANTS
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 April 19, 2000 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 Accounts 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 19, 2000, and with respect to
agreement of security purchases and sales, for the period from
January 1, 2000 through April 19, 2000:
- Confirmation of all securities held by institutions in book
entry form, including the Federal Reserve Bank of Atlanta and the
Depository Trust Company;
- Reconciliation of all such securities to the books and
records of the Company and the custodian; and
- Agreement of nine security purchases and 11 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
April 19, 2000 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 the
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
May 15, 2000
