To the Board of Directors of
Firstar Funds, Inc.
We have examined management's assertion, included in the accompanying Management
Statement Regarding Compliance with Certain Provisions of the Investment Company
Act of 1940, about Firstar Funds, Inc.'s (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 29, 1999. 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 conducted in accordance with attestation 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 29, 1999, and with respect to
agreement of security purchases and sales, for the period from July 30, 1999
(the date of our last examination), through October 29, 1999:
- - Count and inspection of securities located in the vault of Firstar Bank
Milwaukee, N.A. in Milwaukee, Wisconsin;
- - Confirmation of securities held by the following institutions in book entry
form: the Federal Reserve Bank of Chicago and the Depository Trust Company;
- - Confirmation of securities and similar investments held by the following
sub-custodians: Bank of New York and Chase Manhattan Bank;
- - Confirmation of securities and similar investments held by outside brokers and
other third parties;
- - Reconciliation of such securities to the books and records of the Company and
the custodian;
- - Agreement of 5 security purchases and 5 security sales or maturities since
our last report from the books and records of the Company to broker
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 requirements of subsections (b) and (c) of Rule 17f-2 of the
Investment Company Act of 1940 as of October 29, 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 the Board of
Directors, management, and the Securities and Exchange Commission and is not
intended to be and should not be used by anyone other than these specified
parties.
February 9, 2000
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 or 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 October 29, 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 October
29, 1999 with respect to securities and similar investments reflected in the
investment account of the Company.
Firstar Funds, Inc.
By:
/S/ LAURA RAUMAN FEBRUARY 9, 2000
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Laura Rauman Date
Vice President
/S/ JOE NEUBERGER FEBRUARY 9, 2000
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Joe Neuberger Date
Assistant Treasurer
