January 31, 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 December 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 December 31, 1999 and for the period from May 31, 1999 (date
of the last examination) through December 31, 1999, with respect to securities
reflected in the investment accounts of the Funds.
Sincerely,
/S/Signature Omitted
Robert DellaCroce
Controller, Treasurer and Chief Financial Officer
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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 December 31, 1999 and for the
period from May 31, 1999 through December 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 December 31, 1999 and for the period from May 31, 1999 (the date
of our last examination) through December 31, 1999, with respect to securities
transactions, with prior notice to management:
1. Confirmation of all securities held as of December 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 December 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 December 31, 1999 with
brokers/banks and agreement of underlying collateral with the
Huntington Trust Company, N.A. records;
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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 May 31, 1999
through December 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 December 31, 1999 and for the period from May 31, 1999 through
December 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.
[GRAPHIC OMITTED][GRAPHIC OMITTED]
Columbus, Ohio
January 31, 2000
