<PAGE> 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-17f-2
Certificate of Accounting of Securities and Similar
Investments in the Custody of
Management Investment Companies
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
- --------------------------------------------------------------------------------
1. Investment Company Act File Number: Date examination completed:
811-08942 June 30, 1999
- --------------------------------------------------------------------------------
2. State Identification Number:
<TABLE>
<S> <C> <C> <C> <C> <C>
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AL AK AZ AR CA CO
--------------------------------------------------------------------------
CT DE DC FL GA HI
--------------------------------------------------------------------------
ID IL IN IA KS KY
--------------------------------------------------------------------------
LA ME MD MA MI MN
--------------------------------------------------------------------------
MS MO MT NE NV NH
--------------------------------------------------------------------------
NJ NM NY NC ND OH
--------------------------------------------------------------------------
OK OR PA RI SC SD
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TN TX UT VT VA WA
--------------------------------------------------------------------------
WV WI WY PUERTO RICO
--------------------------------------------------------------------------
Other (specify):
--------------------------------------------------------------------------
</TABLE>
- --------------------------------------------------------------------------------
3. Exact name of investment company as specified in registration statement:
First Carolina Investors, Inc.
- --------------------------------------------------------------------------------
- --------------------------------------------------------------------------------
4. Address of principal executive office (number, street, city, state,
zip code):
1130 East Third Street, Suite 410, Charlotte, North Carolina 28204
- --------------------------------------------------------------------------------
INSTRUCTIONS
This Form must be completed by investment companies that have custody of
securities or similar investments.
Investment Company
1. All items must be completed by the investment company.
2. Give this Form to the independent public accountant who, in compliance with
Rule 17f-2 under the Act and applicable state law, examines securities and
similar investments in the custody of the investment company.
Accountant
3. Submit this Form to the Securities and Exchange Commission and appropriate
state securities administrators when filing the certificate of accounting
required by Rule 17f-2 under the Act and applicable state law. File the
original and one copy with the Securities and Exchange Commission's principal
office in Washington, D.C., one copy with the regional office for the region
in which the investment company's principal business operations are
conducted, and one copy with the appropriate state of administrator(s), if
applicable.
THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT
SEC 2198 (11-91)
<PAGE> 2
First Carolina Investors, Inc.
Post Office Box 33607
Charlotte, N.C. 28233-3607
704-373-0501
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
We, as members of management of First Carolina Investors, Inc., are responsible
for complying with the requirements of subsections (b) and (c) of Rule 17f-2,
"Custody of Investments by Registered Management Investment Companies," of the
Investment Company Act of 1940. We are also responsible for establishing and
maintaining effective internal controls over compliance with those
requirements. We have performed an evaluation of the Company's compliance with
the requirements of subsections (b) and (c) of Rule 17f-2 as of June 30, 1999
and from December 31, 1998 through June 30, 1999.
Based on this evaluation, we assert that the Company was in compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company
Act of 1940 as of June 30, 1999 and from December 31, 1998 through June 30,
1999 with respect to securities reflected in the investment account of the
Company.
First Carolina Investors, Inc.
By:
/s/ H. Thomas Webb III
- ----------------------
H. Thomas Webb III
President
<PAGE> 3
[KPMG Letterhead]
401 South Tryon Street
Suite 2300
Charlotte NC 28202-1911
INDEPENDENT AUDITOR'S REPORT
To the Board of Directors of
First Carolina Investors, Inc.
We have examined management's assertion about First Carolina Investors, Inc.
(the "Company's") compliance with the requirements of subsections (b) and (c)
of Rule 17f-2 under the Investment Company Act of 1940 ("the Act") as of June
30, 1999 included in the accompanying Management Statement Regarding Compliance
with Certain Provisions of the Investment Company Act of 1940. Management is
responsible for the Company's compliance with those requirements. Our
responsibility is to express an opinion on management's assertion about the
Company's 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 Company's 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 June 30, 1999, and with respect to agreement of security
purchases and sales, for the period from December 31, 1999 (the date of our
last examination) through June 30, 1999:
- Count and inspection of all securities located at the Company
- Confirmation of all securities held by institutions in book entry form
- Confirmation of all securities out for transfer with brokers
- Reconciliation of all such securities to the books and records of the
Company and the Custodian
We believe that our examination provides a reasonable basis for our opinion.
Our examination does not provide a legal determination on the Company's
compliance with specified requirements.
In our opinion, management's assertion that First Carolina Investors, Inc. was
in compliance with the requirements of subsections (b) and (c) of Rule 17f-2 of
the Investment Company Act of 1940 as of June 30, 1999 with respect to
securities reflected in the investment account of the Company is fairly stated,
in all material respects.
This report is intended solely for the information and use of management, the
Board of Directors of First Carolina Investors, Inc., and the Securities and
Exchange Commission and is not intended to be and should not be used by anyone
other than these specified parties.
/s/ KPMG LLP
Charlotte, North Carolina
February 1, 2000
<PAGE> 4
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-17f-2
Certificate of Accounting of Securities and Similar
Investments in the Custody of
Management Investment Companies
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
- --------------------------------------------------------------------------------
1. Investment Company Act File Number: Date examination completed:
811-08942 October 31, 1999
- --------------------------------------------------------------------------------
2. State Identification Number:
<TABLE>
<S> <C> <C> <C> <C> <C>
--------------------------------------------------------------------------
AL AK AZ AR CA CO
--------------------------------------------------------------------------
CT DE DC FL GA HI
--------------------------------------------------------------------------
ID IL IN IA KS KY
--------------------------------------------------------------------------
LA ME MD MA MI MN
--------------------------------------------------------------------------
MS MO MT NE NV NH
--------------------------------------------------------------------------
NJ NM NY NC ND OH
--------------------------------------------------------------------------
OK OR PA RI SC SD
--------------------------------------------------------------------------
TN TX UT VT VA WA
--------------------------------------------------------------------------
WV WI WY PUERTO RICO
--------------------------------------------------------------------------
Other (specify):
--------------------------------------------------------------------------
</TABLE>
- --------------------------------------------------------------------------------
3. Exact name of investment company as specified in registration statement:
First Carolina Investors, Inc.
- --------------------------------------------------------------------------------
- --------------------------------------------------------------------------------
4. Address of principal executive office (number, street, city, state,
zip code):
1130 East Third Street, Suite 410, Charlotte, North Carolina 28204
- --------------------------------------------------------------------------------
INSTRUCTIONS
This Form must be completed by investment companies that have custody of
securities or similar investments.
Investment Company
1. All items must be completed by the investment company.
2. Give this Form to the independent public accountant who, in compliance with
Rule 17f-2 under the Act and applicable state law, examines securities and
similar investments in the custody of the investment company.
Accountant
3. Submit this Form to the Securities and Exchange Commission and appropriate
state securities administrators when filing the certificate of accounting
required by Rule 17f-2 under the Act and applicable state law. File the
original and one copy with the Securities and Exchange Commission's principal
office in Washington, D.C., one copy with the regional office for the region
in which the investment company's principal business operations are
conducted, and one copy with the appropriate state of administrator(s), if
applicable.
THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT
SEC 2198 (11-91)
<PAGE> 5
First Carolina Investors, Inc.
Post Office Box 33607
Charlotte, N.C. 28233-3607
704-373-0501
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
We, as members of management of First Carolina Investors, Inc., are responsible
for complying with the requirements of subsections (b) and (c) of Rule 17f-2,
"Custody of Investments by Registered Management Investment Companies," of the
Investment Company Act of 1940. We are also responsible for establishing and
maintaining effective internal controls over compliance with those requirements.
We have performed an evaluation of the Company's compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 as of October 31, 1999 and
from June 30, 1999 through October 31, 1999.
Based on this evaluation, we assert that the Company was in compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company
Act of 1940 as of October 31, 1999 and from June 30, 1999 through October 31,
1999 with respect to securities reflected in the investment account of the
Company.
First Carolina Investors, Inc.
By:
/s/ H. Thomas Webb III
- ----------------------
H. Thomas Webb III
President
<PAGE> 6
[KPMG Letterhead]
401 South Tryon Street
Suite 2300
Charlotte NC 28202-1911
INDEPENDENT AUDITOR'S REPORT
To the Board of Directors of
First Carolina Investors, Inc.
We have examined management's assertion about First Carolina Investors, Inc.
(the "Company's") compliance with the requirements of subsections (b) and (c) of
Rule 17f-2 under the Investment Company Act of 1940 ("the Act") as of October
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 Company's compliance with those requirements. Our
responsibility is to express an opinion on management's assertion about the
Company's 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 Company's 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 October 31, 1999, and with respect to agreement of security
purchases and sales, for the period from June 30, 1999 (the date of our
last examination) through October 31, 1999:
- Count and inspection of all securities located at the Company
- Confirmation of all securities held by institutions in book entry form
- Confirmation of all securities out for transfer with brokers
- Reconciliation of all such securities to the books and records of the
Company and the Custodian
We believe that our examination provides a reasonable basis for our opinion.
Our examination does not provide a legal determination on the Company's
compliance with specified requirements.
In our opinion, management's assertion that First Carolina Investors, Inc. was
in compliance with the requirements of subsections (b) and (c) of Rule 17f-2 of
the Investment Company Act of 1940 as of October 31, 1999 with respect to
securities reflected in the investment account of the Company is fairly stated,
in all material respects.
This report is intended solely for the information and use of management, the
Board of Directors of First Carolina Investors, Inc., and the Securities and
Exchange Commission and is not intended to be and should not be used by anyone
other than these specified parties.
/s/ KPMG LLP
Charlotte, North Carolina
February 1, 2000
<PAGE> 7
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-17f-2
Certificate of Accounting of Securities and Similar
Investments in the Custody of
Management Investment Companies
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
- --------------------------------------------------------------------------------
1. Investment Company Act File Number: Date examination completed:
811-08942 December 31, 1999
- --------------------------------------------------------------------------------
2. State Identification Number:
<TABLE>
<S> <C> <C> <C> <C> <C>
--------------------------------------------------------------------------
AL AK AZ AR CA CO
--------------------------------------------------------------------------
CT DE DC FL GA HI
--------------------------------------------------------------------------
ID IL IN IA KS KY
--------------------------------------------------------------------------
LA ME MD MA MI MN
--------------------------------------------------------------------------
MS MO MT NE NV NH
--------------------------------------------------------------------------
NJ NM NY NC ND OH
--------------------------------------------------------------------------
OK OR PA RI SC SD
--------------------------------------------------------------------------
TN TX UT VT VA WA
--------------------------------------------------------------------------
WV WI WY PUERTO RICO
--------------------------------------------------------------------------
Other (specify):
--------------------------------------------------------------------------
</TABLE>
- --------------------------------------------------------------------------------
3. Exact name of investment company as specified in registration statement:
First Carolina Investors, Inc.
- --------------------------------------------------------------------------------
- --------------------------------------------------------------------------------
4. Address of principal executive office (number, street, city, state,
zip code):
1130 East Third Street, Suite 410, Charlotte, North Carolina 28204
- --------------------------------------------------------------------------------
INSTRUCTIONS
This Form must be completed by investment companies that have custody of
securities or similar investments.
Investment Company
1. All items must be completed by the investment company.
2. Give this Form to the independent public accountant who, in compliance with
Rule 17f-2 under the Act and applicable state law, examines securities and
similar investments in the custody of the investment company.
Accountant
3. Submit this Form to the Securities and Exchange Commission and appropriate
state securities administrators when filing the certificate of accounting
required by Rule 17f-2 under the Act and applicable state law. File the
original and one copy with the Securities and Exchange Commission's principal
office in Washington, D.C., one copy with the regional office for the region
in which the investment company's principal business operations are
conducted, and one copy with the appropriate state of administrator(s), if
applicable.
THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT
SEC 2198 (11-91)
<PAGE> 8
First Carolina Investors, Inc.
Post Office Box 33607
Charlotte, N.C. 28233-3607
704-373-0501
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
We, as members of management of First Carolina Investors, Inc., are responsible
for complying with the requirements of subsections (b) and (c) of Rule 17f-2,
"Custody of Investments by Registered Management Investment Companies," of the
Investment Company Act of 1940. We are also responsible for establishing and
maintaining effective internal controls over compliance with those requirements.
We have performed an evaluation of the Company's compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 as of December 31, 1999
and from October 31, 1999 through December 31, 1999.
Based on this evaluation, we assert that the Company was 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 from October 31, 1999 through December
31, 1999 with respect to securities reflected in the investment account of the
Company.
First Carolina Investors, Inc.
By:
/s/ H. Thomas Webb III
- ----------------------
H. Thomas Webb III
President
<PAGE> 9
[KPMG Letterhead]
401 South Tryon Street
Suite 2300
Charlotte NC 28202-1911
INDEPENDENT AUDITOR'S REPORT
To the Board of Directors of
First Carolina Investors, Inc.
We have examined management's assertion about First Carolina Investors, Inc.
(the "Company's") 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 included in the accompanying Management Statement Regarding Compliance
with Certain Provisions of the Investment Company Act of 1940. Management is
responsible for the Company's compliance with those requirements. Our
responsibility is to express an opinion on management's assertion about the
Company's 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 Company's 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 with respect to agreement of security
purchases and sales, for the period from October 31, 1999 (the date of our
last examination) through December 31, 1999:
- Count and inspection of all securities located at the Company
- Confirmation of all securities held by institutions in book entry form
- Confirmation of all securities out for transfer with brokers
- Reconciliation of all such securities to the books and records of the
Company and the Custodian
We believe that our examination provides a reasonable basis for our opinion.
Our examination does not provide a legal determination on the Company's
compliance with specified requirements.
In our opinion, management's assertion that First Carolina Investors, Inc. was
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 with respect to
securities reflected in the investment account of the Company is fairly stated,
in all material respects.
This report is intended solely for the information and use of management, the
Board of Directors of First Carolina Investors, Inc., and the Securities and
Exchange Commission and is not intended to be and should not be used by anyone
other than these specified parties.
/s/ KPMG LLP
Charlotte, North Carolina
February 1, 2000
