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Certificate of Accounting of Securities and Similar
Investments in the Custody of
Management Investment Companies
Pursuant to Rule 17f-2 (17 CPR 270 17F-2)
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OMB APPROVAL
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OMB Number: 3235-0360
Expires: July 31, 1994
Estimated average burden
hours per response . . . 0.05
__________________________________________________
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1. Investment Company Act file Number:
Date examination completed:
811-6076 9/30/99
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2. State identification Number:
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<S> <C> <C> <C> <C> <C>
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AL AK AZ AR CA CO
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CT DE DC FL GA HI
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ID IL IN IA KS KY
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LA ME MD MA MI MN
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MS MO MT NE NV NH
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NJ NM NY NC ND OH
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OK OR PA RI SC SD
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TN TX UT VT VA WA
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WV WI WY PUERTO RICO
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Other (specify):
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3. Exact name of investment company as specified in registration statement:
Infinity Mutual Funds - ISG Funds
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5. Address of principal executive office (number, street, city, state, zip
code):
JEFFREY C. CUSICK, BISYS FUND SERVICES,
3435 STELZER ROAD, COLUMBUS, OHIO 43219-8001
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INSTRUCTIONS
This form must be completed by investment companies that have custody of
securities or similar investments
Investment Company
<PAGE>
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
SEC 2198 (11-91)
<PAGE>
The Infinity Mutual Funds, Inc.
3435 Stelzer Road
Columbus, Ohio 43219
December 17, 1999
Management Statement Regarding Compliance with Certain Provisions of the
Investment Company Act of 1940
We, as members of management of The Infinity Mutual Funds, Inc. - ISG Funds (the
Funds), are responsible for complying with the requirements of subsections (b)
and (c) of Rule 17f-2, "Custody of Investments by Registered Investment
Companies," of the Investment Company Act of 1940. We are also responsible for
establishing and maintaining effective internal controls over compliance with
Rule 17f-2 requirements. We have performed an evaluation of the Funds'
compliance with the requirements of subsections (b) and (c) of Rule 17f-2 as of
September 30, 1999.
Based on this evaluation, we assert that the Funds were in compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company
Act of 1940 as of September 30, 1999 and for the period January 1, 1999 through
September 30, 1999, with respect to securities reflected in the investment
accounts of the Funds.
Sincerely,
/s/ JEFFREY C. CUSICK
Jeffrey C. Cusick
Vice President
The Infinity Mutual Funds, Inc.
<PAGE>
To the Board of Directors of
The Infinity Mutual Funds, Inc. - ISG Funds
and the
Securities and Exchange Commission:
We have examined management's assertion about The Infinity Mutual Funds, Inc. -
ISG Funds (the Funds) compliance with the requirements of subsections (b) and
(c) of Rule 17f-2 under the Investment Company Act of 1940 (the Act) as of
September 30, 1999 and for the period from January 1, 1999 through September 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 Funds' compliance with those requirements. Our
responsibility is to express an opinion on management's assertion about the
Funds' 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 Funds' 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 September 30, 1999 and for the period from January 1, 1999
through September 30, 1999, with respect to securities transactions:
1. Confirmation of all securities held as of September 30, 1999 by the
Bank of New York, without prior notice to management;
2. Verification of all securities purchased/sold but not
received/delivered and securities in transit as of September 30, 1999
via examination of underlying trade ticket, broker confirmation, or
cash settlement;
3. Reconciliation of all such securities to the books and records of the
Funds and the Bank of New York;
4. Confirmation of all repurchase agreements as of September 30, 1999
with brokers/banks and agreement of underlying collateral with the
Bank of New York records; and
5. Agreement of 10 selected security purchases/sales from the books and
records of the Funds to broker confirmations during the period from
January 1, 1999 through September 30, 1999.
We believe that our examination provides a reasonable basis for our opinion. Our
examination does not provide a legal determination on the Funds' compliance with
specified requirements.
<PAGE>
2
In our opinion, management's assertion that the Funds were in compliance with
the above mentioned provisions of Rule 17f-2 of the Investment Company Act of
1940 as of September 30, 1999 and for the period from January 1, 1999 through
September 30, 1999 is fairly stated, in all material respects.
This report is intended solely for the information and use of management of the
Funds and the Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.
KPMG LLP
Columbus, Ohio
December 17, 1999
