HIBERNIA FUNDS
40-17F2, 1999-01-13
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                     U.S. 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-    5536                                              1/1/98 - 3/31/98




2.  State Identification Number:

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):

3.  Exact name of investment company as specified in registration statement:

 TOWER MUTUAL FUNDS            

4.  Address of principal executive office:  (number, street, city, state,
    zip code)

    FEDERATED INVESTORS TOWER, PITTSBURGH, PA  15222-3379         

INSTRUCTIONS

     This Form must be completed by the 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 administrator(s), if
applicable.

THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT

     Note: The estimated average burden hours are made solely for purposes of
the Paperwork Reduction Act, and are not derived from a comprehensive or even a
representative survey or study of the costs of SEC rules and forms. Direct any
comments concerning the accuracy of the estimated average burden hours for
compliance with SEC rules and forms to Kenneth A. Fogash, Deputy Executive
Director, U.S. Securities and Exchange Commission, 450 Fifth Street, N.W.,
Washington, D.C. 20549 and Gary Waxman, Clearance Officer, Office of Management
and Budget, Room 3208 New Executive Office Building, Washington, D.C. 20503.


<PAGE>





Management Statement Regarding Compliance with

CERTAIN PROVISIONS OF THE INVESTMENT COMPANY ACT OF 1940

     We, as members of management of The Tower Mutual Funds (the "Funds"), are
responsible for complying with the requirements of subsection (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 controls over compliance with those
requirements. We have performed an evaluation of the Company's compliance with
the requirements of subsection (b) and (c) of Rule 17f-2 from January 1, 1998
through March 31, 1998.

     Based on this evaluation, we assert that the Funds were in compliance with
the requirements of subsection (b) and (c) of Rule 17f-2 of the Investment
Company Act of 1940 from January 1, 1998 through March 31, 1998, with respect to
securities and similar investments reflected in the investment account of the
Company.

                                            By:    /S/  KENNETH A. RAINS
                                                   Kenneth A. Rains
                                                   Executive Vice President
                                                   Hibernia National Bank

                                                   /S/  JEFFREY W. STERLING
                                                   Jeffrey W. Sterling
                                                   Assistant Treasurer
                                                   Tower Mutual Funds




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