HUNTINGTON FUNDS /MA/
40-17F2, 2000-06-12
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April 7, 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 February 29, 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 February  29, 2000 and for the period from  December  31, 1999
(date of the last  examination)  through  February  29,  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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