[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]
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1. Investment Company Act File Number:
333-44511
Date examination completed: April 16, 1999
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2. State identification Number: N/A
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AL AK AZ AR CA CO
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CT DE DC FL GA HI
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ID IL IN IA KS KY
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LA ME MD MA MI MN
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MS MO MT NE NV NH
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NJ NM NY NC ND OH
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OK OR PA RI SC SD
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TN TX UT VT VA WA
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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 registration statement:
Huntington Funds
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4. Address of principal executive office (number, street, city, state, zip code)
680 Swedesford Road, Wayne, PA, 19087-1693
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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
March 31, 1999 and for the period from December 31, 1998 through
March 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 March 31, 1999
and for the period from December 31, 1998 (the date of our last examination)
through March 31, 1999, with respect to securities transactions, with prior
notice to management:
1. Confirmation of all securities held as of March 31, 1998 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 March 31, 1998 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, 1998
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 December 31, 1998 through
March 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 March 31, 1999 and for the period from December 31, 1998
through March 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
April 16, 1999
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