July 9, 1999
Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act
of 1940
We, as members of management of The Huntington 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 control 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
May 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 May 31, 1999 and for the
period from March 31, 1999 (date of the last examination) through
May 31, 1999, with respect to securities reflected in the investment
accounts of the Funds.
Sincerely,
Robert DellaCroce
Controller, Treasurer and Chief Financial Officer
Page 1
July 7, 1999
To the Board of Trustees of
The Huntington Funds
and the
Securities and Exchange Commission:
We have examined management's assertion about The Huntington 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
May 31, 1999 and for the period from March 31, 1999 through May 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
1941. 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 May 31, 1999 and for the period from
March 31, 1999 (the date of our last examination) through May 31,
1999, with respect to securities transactions, with prior notice to management:
1. Confirmation of all securities held as of May 31, 1999 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 May 31, 1999 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 May 31, 1999 with
brokers/banks and agreement of underlying collateral with the Huntington
Trust Company, N.A. records;
5. Agreement of 5 selected security purchases and 5 selected security
sales since our last report date from the books and records of the Funds
to broker confirmations during the period from March 31, 1999 through
May 31,1999.
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 May 31, 1999 and for the period from March
31, 1999 through May 31, 1999 is fairly stated, in all material respects.
This report is intended solely for the information and use of management of the
Funds and the Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than the specified parties.
Columbus, Ohio
July 9, 1999
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