ANAGEMENT STATEMENT REGARDING COMPLIANCE WITH CERTAIN PROVISIONS OF THE
INVESTMENT COMPANY ACT OF 1940
We, as members of management of Firstar Stellar Funds (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 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,
2000, and from July 28, 2000 through October 31, 2000.
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, 2000, and from July 28, 2000 through October 31,
2000, with respect to securities reflected in the investment account of the
Company, except that for several securities the books of the Company did not
agree to the Custodian records. These exceptions were the result of the untimely
recording of security transactions in the Custodian records. In each case the
books of the Company were determined to be proper and the Custodian records have
been subsequently corrected.
FIRSTAR STELLAR FUNDS
By: /s/ Joe Neuberger
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Name of Company Official
Vice President
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Title
12/21/00
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Date
By: /s/ Elaine E. Richards
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Name of Company Official
Secretary
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Title
12/21/00
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Date
