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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 ex
811-4852 6-9-00
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2. State identification Number:
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AL AK AZ AR
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CT DE DC FL
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ID IL IN IA
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LA ME MD MA
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MS MO MT NE
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NJ NM NY NC
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OK OR PA RI
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TN TX UT VT
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WV WI WY PUERTO RICO
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Other (specify):
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3. Exact name of investment company as specified in representation statement:
The Victory Portfolios
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5. Address of principal executive office (number, street, city, state, zip
code):
BISYS FUND SERVICES, 3435 STELZER ROAD, COLUMBUS, OHIO 43219-8001
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INSTRUCTIONS
This form must be completed by investment companies that have custody of
securities or similar investments.
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
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[LETTERHEAD]
Report of Independent Accountants
To the Trustees of
The Victory Portfolios:
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 Victory Portfolios' (constituting the Institutional Money
Market Fund, Federal Money Market Fund, U.S. Government Obligations Fund, Prime
Obligations Fund, Financial Reserves Fund, Tax-Free Money Market Fund, Ohio
Municipal Money Market Fund, Limited Term Income Fund, Intermediate Income Fund,
Fund For Income Fund, Investment Quality Bond Fund, National Municipal Bond
Fund, New York Tax-Free Fund, Ohio Municipal Bond Fund, Balanced Fund,
Convertible Securities Fund, Real Estate Investment Fund, Value Fund, Lakefront
Fund, Established Value Fund, Diversified Stock Fund, Stock Index Fund, Growth
Fund, Special Value Fund, Small Company Opportunity Fund, International Growth
Fund, LifeChoice Moderate Investor Fund, LifeChoice Growth Investor Fund, and
LifeChoice Conservative Investor Fund) compliance with the requirements of
subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940
("the Act") as of June 9, 2000. Management is responsible for The Victory
Portfolios' compliance with those requirements. Our responsibility is to express
an opinion on management's assertion about The Victory Portfolios' compliance
based on our examination.
Our examination was 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 Victory
Portfolios' 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 June 9, 2000, and with
respect to agreement of security purchases and sales, for the period of October
31, 1999 (the date of our last examination), through June 9, 2000:
- Count and inspection of all securities located in the vault of Key Trust
Company of Ohio, N.A. in Cleveland, Ohio, without prior notice to management;
- Confirmation of all securities held by institutions in book entry from the
Federal Reserve Bank of Cleveland, the Depository Trust Company, or Bank of
New York;
- Confirmation of all securities out for transfer with brokers;
- Confirmation, or other procedures as we considered necessary, of all mutual
fund investments with transfer agents;
- Reconciliation of all such securities to the books and records of The Victory
Portfolios and the Custodian;
- Confirmation of all repurchase agreements with brokers/banks and agreement of
underlying collateral with Key Trust Company of Ohio, N.A.'s records; and
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[LOGO]
We believe that our examination provides a reasonable basis for our opinion. Our
examination does not provide a legal determination on The Victory Portfolios'
compliance with specified requirements.
In our opinion, management's assertion that The Victory Portfolios' were in
compliance with the requirements of subsections (b) and (c) of Rule 17f-2 of the
Investment Company Act of 1940 as of June 9, 2000, with respect to securities
reflect to securities reflected in the investment account of The Victory
Portfolios' are fairly stated, in all material respects.
The report is intended solely for the information and use of the 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.
PriceWaterhouseCooper LLP
August 23, 2000
2
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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 Victory Portfolios (constituting the
Institutional Money Market Fund, Federal Money Market Fund, U.S. Government
Obligations Fund, Prime Obligations Fund, Financial Reserves Fund, Tax-Free
Money Market Fund, Ohio Municipal Money Market Fund, Limited Term Income Fund,
Intermediate Income Fund, Fund for Income Fund, Investment Quality Bond Fund,
National Municipal Bond Fund, New York Tax-Free Fund, Ohio Municipal Bond Fund,
Balanced Fund, Convertible Securities Fund, Real Estate Investment Fund, Value
Fund, Lakefront Fund, Established Value Fund, Diversified Stock Fund, Stock
Index Fund, Growth Fund, Special Value Fund, Small Company Opportunity Fund,
International Growth Fund, LifeChoice Moderate Investor Fund, LifeChoice Growth
Investor Fund, and LifeChoice Conservative Investor Fund), 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 Victory Portfolios' compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 as of June 9, 2000, and
from October 31, 1999 through June 9, 2000.
Based on this evaluation, we assert that The Victory Portfolios were in
compliance with the requirements of subsections (b) and (c) of Rule 17f-2 of the
Investment Company Act of 1940 as of June 9, 2000, and from October 31, 1999,
through June 9, 2000, with respect to securities reflected in the investment
account of The Victory Portfolios.
The Victory Portfolios.
