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REPUBLIC FUNDS
3435 Stelzer Road
Columbus, Ohio 43219
December 27, 1999
MANAGEMENT STATEMENT REGARDING COMPLIANCE WITH CERTAIN PROVISIONS OF THE
INVESTMENT COMPANY ACT OF 1940
We, as members of management of the Republic Funds (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 August 31, 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 August 31, 1999 and for the period from October 31, 1998
through August 31, 1999, with respect to securities reflected in the investment
accounts of the Funds.
Sincerely,
Walter B. Grimm
President
Republic Funds
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To the Board of Trustees of
Republic Funds
and the
Securities and Exchange Commission:
We have examined management's assertion about the Republic Funds' (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 August 31, 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 Funds' 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 August 31, 1999, and with respect to agreement of security
purchases and sales, for the period from October 31, 1998 through August 31,
1999:
1. Confirmation of all securities held by Republic Bank of New York
(Republic Bank) in book entry form without prior notice;
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 Republic Bank;
4. Confirmation of all repurchase agreements with brokers/banks and
agreement of underlying collateral with the Republic Bank's records;
and
5. Agreement of four selected security purchases, sales or maturities from
the books and records of the Funds to broker confirmations or trade
tickets.
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 August 31, 1999, with respect to securities reflected
in the investment account of the Funds is fairly stated, in all material
respects.
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This report is intended solely for the information and use of management of the
Republic Funds and the Securities and Exchange Commission and is not intended to
be and should not be used by anyone other than these specified parties.
Columbus, Ohio
December 27, 1999
