To the Board of Directors of
Firstar Funds, Inc.
We have examined management's assertion about Firstar Funds, Inc.'s (the
"Company") compliance with the requirements of subsections (b) and (c) of Rule
17f-2 under the Investment Company Act of 1940 ("the Act") as of July 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 July 30, 1999, and for the period from March 27, 1999 through
July 30, 1999 with respect to the agreement of purchase and sales of securities
and similar investments, without prior notice to management:
o Count and inspection of all securities and similar investments located
in the vault of the Firstar Bank Milwaukee, N.A. in
Milwaukee, Wisconsin;
o Confirmation of all securities and similar investments held by the
following institutions in book entry form: the Federal
Reserve Bank of Chicago and the Depository Trust Company;
o Confirmation of all securities and similar investments held by the
following subcustodians: Bank of New York and Chase
Manhattan Bank;
o Confirmation of all securities and similar investments held by outside
brokers and other third parties;
o Reconciliation of count, inspection, and confirmation results as to
all such securities and similar investments to the books
of the Company; and
o Agreement of 5 investment purchases and 5 investment sales since our last
examination from the books and records of the Company to trade
confirmations.
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 Firstar Funds, Inc. was in
compliance with the above mentioned provisions of Rule 17f-2 of the Investment
Company Act of 1940 as of July 30, 1999 is fairly stated, in all material
respects.
This report is intended solely for the information and the use of management of
Firstar Funds, Inc. and the Securities and Exchange Commission and should not be
used for any other purpose.
October 12, 1999
Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940
We, as members of management of Firstar Funds, Inc. (the "Company"), 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 an effective internal control structure 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 July 30, 1999.
Based on this evaluation, we assert that the Company was in compliance with
those provisions of Rule 17f-2 of the Investment Company Act of 1940 as of July
30, 1999 with respect to securities and similar investments reflected in the
investment account of the Company, except that for three securities the books of
the Company did not agree to the custodian records. In each case the custodian
records were determined to be proper and the books of the Company have been
subsequently corrected to reflect the proper shares or par value owned.
Firstar Funds, Inc.
By:
/s/Laura Rauman
10/12/99
Laura Rauman Date
Vice President
/s/Joe Neuberger
10/12/99
Joe Neuberger Date
Assistant Treasurer
fsrfunds\pwcount3.sam
