EXHIBIT INDEX
Exhibit A: Attachment to item 77B:
Accountants report on internal control
Exhibit B: Attachment to item 77O:
Transactions effected pursuant to Rule 10f-3
-------------------------------------------------------
Exhibit A:
Report of Independent Accountants
To the Board of Trustees and Shareholders
of The Gabelli Westwood Funds:
In planning and performing our audit of the financial statements
of The Gabelli Westwood Funds (comprised of The Gabelli Westwood
Equity Fund, The Gabelli Westwood Balanced Fund, The Gabelli
Westwood Intermediate Bond Fund, The Gabelli Westwood SmallCap
Equity Fund, The Gabelli Westwood Realty Fund, and The Gabelli
Westwood Mighty Mites Fund, collectively the "Fund") for the year
ended September 30, 2000, we considered its internal control,
including control activities for safeguarding securities, in
order to determine our auditing procedures for the purpose of
expressing our opinion on the financial statements and to comply
with the requirements of Form N-SAR, not to provide assurance on
internal control.
The management of the Fund is responsible for establishing and
maintaining internal control. In fulfilling this responsibility,
estimates and judgments by management are required to assess the
expected benefits and related costs of controls. Generally,
controls that are relevant to an audit pertain to the entity's
objective of preparing financial statements for external purposes
that are fairly presented in conformity with generally accepted
accounting principles. Those controls include the safeguarding
of assets against unauthorized acquisition, use or disposition.
Because of inherent limitations in internal control, errors or
fraud may occur and not be detected. Also, projection of any
evaluation of internal control to future periods is subject to
the risk that controls may become inadequate because of changes
in conditions or that the effectiveness of their design and
operation may deteriorate.
Our consideration of internal control would not necessarily
disclose all matters in internal control that might be material
weaknesses under standards established by the American Institute
of Certified Public Accountants. A material weakness is a
condition in which the design or operation of one or more of the
internal control components does not reduce to a relatively low
level the risk that misstatements caused by error or fraud in
amounts that would be material in relation to the financial
statements being audited may occur and not be detected within a
timely period by employees in the normal course of performing
their assigned functions. However, we noted no matters involving
internal control and its operation, including controls for
safeguarding securities, that we consider to be material
weaknesses as defined above as of September 30, 2000.
This report is intended solely for the information and use of the
Board of Trustees, 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.
PricewaterhouseCoopers LLP
November 14, 2000
Exhibit B:
THE GABELLI WESTWOOD SMALL CAP EQUITY FUND
2ND QUARTER 2000
SECTION 10F-3 TRANSACTIONS
The following securities were purchased pursuant to Rule 10f-3 and all
requirements of the Affiliated Underwriting Procedures of the Fund. A
folder documenting such compliance for each transaction is available for
inspection by Board Members.
Trade Dates 05-18-00
Issue US Unwired
Shares 10,000
Price $11
Amount $110,000
Spread Amount 0.77
Spread % 7.0%
Fund's % of Issue 0.13%
% of Issue for all
Westwood Funds 0.13%
Broker Donaldson Lufkin & Jenrette
Issues within 90 days 3
Reason (1),(2)
Trade Dates 06-27-00
Issue Genuity
Shares 5,000
Price $11
Amount $55,000
Spread Amount 0.434
Spread % 3.95%
Fund's % of Issue 0.00%
% of Issue for all
Westwood Funds 0.00%
Broker Morgan Stanley
Issues within 90 days 3
Reason (1),(2)
The Purchases listed above meet the following requirements of 10f-3
...Part of an issue registered under the Securities Act of 1933.
...Purchased at not more than the offering price.
...Offered pursuant to a firm commitment underwriting.
...The issuer has been in continuos operation for at least 3 years.
All other requirements are presented in the table above.
Reason Key
(1) Does not exceed 125% of the mean offering spread of 3 comparable
Issues underwritten in the last 90 days.
(2) Does not exceed 110% of this underwriting spread of 3 comparable
Issues underwritten in the last 90 days.
Note: If 3 comparable issues are not available within 90 days, a one-year
window is used.
THE GABELLI WESTWOOD SMALL CAP EQUITY FUND
3RD QUARTER 2000
SECTION 10F-3 TRANSACTIONS
The following securities were purchased pursuant to Rule 10f-3 and all
requirements of the Affiliated Underwriting Procedures of the Fund. A
folder documenting such compliance for each transaction is available for
inspection by Board Members.
Trade Dates 08-02-00
Issue California Pizza Kitchen
Shares 200
Price $15
Amount $3,000
Spread Amount 1.05
Spread % 7.0%
Fund's % of Issue 0.00%
% of Issue for all
Westwood Funds 0.00%
Broker Bank America
Issues within 90 days 3
Reason (1),(2)
The Purchases listed above meet the following requirements of 10f-3
...Part of an issue registered under the Securities Act of 1933.
...Purchased at not more than the offering price.
...Offered pursuant to a firm commitment underwriting.
...The issuer has been in continuos operation for at least 3 years.
All other requirements are presented in the table above.
Reason Key
(1) Does not exceed 125% of the mean offering spread of 3 comparable
Issues underwritten in the last 90 days.
(2) Does not exceed 110% of this underwriting spread of 3 comparable
Issues underwritten in the last 90 days.
Note: If 3 comparable issues are not available within 90 days, a one-year
window is used.
