HUNTINGTON FUNDS /MA/
40-17F2, 2000-09-26
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July 5, 2000



    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, 2000.

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, 2000 and for the period from February 29, 2000 (date
of the last examination) through May 31, 2000, with respect to securities
reflected in the investment accounts of the Funds.


Sincerely,




John Leven
Treasurer and Chief Financial Officer




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