MONITOR FUNDS
40-17F2, 1998-03-12
Previous: BANK OF GRANITE CORP, PRE 14A, 1998-03-12
Next: OXFORD FUTURES FUND LTD, 10-K, 1998-03-12




                                                                  [C]
          SECURITIES AND EXCHANGE COMMISSION            ------------------------
                WASHINGTON, D.C. 20549                            OMB Approval
                     FORM N-17f-2                       ------------------------
                                                        OMB Number   3235-0360
   Certificate of Accounting of Securities and Similar  Expires:  July 31, 1994
             Investments in the Custody of              Estimated average burden
            Management Investment Companies             hours per response. 0.05

        Pursuant to Rule 17f-2 [17 CFR 270.17f-2]

- -----------------------------------------------------------------------------
1. Investment Company Act File Number:    
    
     333-44511

   Date examination completed:  February 13, 1998

- -----------------------------------------------------------------------------
2. State identification Number:  N/A
   --------------------------------------------------------------------------
     AL        AK        AZ        AR       CA        CO       
   --------------------------------------------------------------------------
     CT        DE        DC        FL       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:
	The Monitor Funds
      
- ----------------------------------------------------------------------------


- ----------------------------------------------------------------------------
4.Address of principal executive office (number,street,city,state,zip code)

          680 Swedesford Road, Wayne, PA, 19087-1693
- ---------------------------------------------------------------------------- 
                                                                              







Exhibit 23



To the Trustees of
The Monitor Funds
	and the
Securities and Exchange Commission:


We have examined management's assertion about The Monitor Funds' (the Funds) 
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, 1997 
and for the period from June 30, 1997 through December 31, 1997, 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 December 31, 1997 and for the 
period from June 30, 1997 (the date of our last examination) through 
December 31, 1997, with respect to securities transactions:

   1. Confirmation of all securities held as of December 31, 1997 by 
      institutions in book entry form by the Federal Reserve Bank, 
      Bank of New York, and Depository Trust Corporation;

   2. Verification of all securities purchased/sold but not 
      received/delivered and securities in transit as of 
      December 31, 1997 via examination of underlying trade ticket 
      or broker confirmation;

   3. Reconciliation of all such securities to the books and records 
      of the Funds and The Huntington Trust Company, N.A.;

   4. Confirmation of all repurchase agreements as of December 31, 1997 
      with brokers/banks and agreement of underlying collateral with 
      The Huntington Trust Company, N.A. records; and

   5. Agreement of selected security purchases, sales or maturities 
      since our last report date from the books and records of the 
      Funds 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 Funds' 
compliance with specified requirements.

In our opinion, management's assertion that the Funds were in compliance 
with the above mentioned provisions of Rule 17f-2 of the Investment Company 
Act of 1940 as of December 31, 1997 and for the period from June 30, 1997 
through December 31, 1997 is fairly stated, in all material respects.

This report is intended solely for the information and use of management of 
The Monitor Funds and the Securities and Exchange Commission and should not 
be used for any other purpose.



/s/ KPMG PEAT MARWICK LLP
- -------------------------
KPMG Peat Marwick LLP

Columbus, Ohio
February 13, 1998





           Management Statement Regarding Compliance with
      Certain Provisions of the Investment Company Act of 1940


We, as members of management of The Monitor Funds ("the Funds") 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 an effective internal control structure 
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 December 31, 1997.

Based on the 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 December 31, 1997, with respect to securities 
reflected in the investment accounts of the Funds.

The Monitor Funds

/s/ ROBERT DELLACROSE
- ---------------------
Robert DellaCroce
Controller, Treasurer and Chief Financial Officer













© 2022 IncJournal is not affiliated with or endorsed by the U.S. Securities and Exchange Commission