[C]
SECURITIES AND EXCHANGE COMMISSION ------------------------
WASHINGTON, D.C. 20549 OMB Approval
FORM N-17f-2 ------------------------
OMB Number 3235-0360
Certificate of Accounting of Securities and Similar Expires: July 31, 1994
Investments in the Custody of Estimated average burden
Management Investment Companies hours per response. 0.05
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
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1. Investment Company Act File Number:
811-06114
Date examination completed: August 29, 1997
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2. State identification Number: N/A
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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:
AMERICAN PERFORMANCE FUNDS
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4. Address of principal executive office (number, street, city, state, zip code)
3435 Stelzer Rd, Ste 1000, Columbus, OH, 43219
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EXHIBIT 23
To the Board of Directors of
American Performance Funds
and the
Securities and Exchange Commission:
We have examined management's assertion about the American Performance
Funds' (the Funds) compliance with the requirements of subsection (b) and
(c) of Rule 17f-2 under the Investment Company Act of 1940 (the Act) as of
August 29, 1997 and for the period from July 31, 1997 through
August 29, 1997, 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 August 29, 1997 and for the period
from July 31, 1997 (the date of our last examination) through
August 29, 1997, with respect to securities transactions, without prior
notice to management:
1. Confirmation of all securities held as of August 29, 1997 by
subcustodians;
2. Verification of all securities purchased/sold but not received/delivered
and securities in transit as of August 29, 1997 via examination of
underlying trade ticket or broker confirmation;
3. Reconciliation of all such securities to the books and records of the
Funds and the BancOklahoma Trust Company;
4. Confirmation of all repurchase agreements as of August 29, 1997 with
brokers/banks and agreement of underlying collateral with the BancOklahoma
Trust Company records; and
5. Agreement of five selected security purchases, sales or maturities
since our last report date from the books and records of the Funds 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
Funds' compliance with specified requirements.
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 August 29, 1997 and for the period from July 31, 1997
through August 29, 1997 is fairly stated, in all material respects.
This report is intended solely for the information and use of management of
the American Performance Funds and the Securities and Exchange Commission
and should not be used for any other purpose.
/s/ KPMG PEAT MARWICK LLP
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KPMG Peat Marwick LLP
Columbus, Ohio
September 18, 1997
September 18, 1997
Re: Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940
We, as members of management of The American Performance Funds ("the Funds"),
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 Rule 17f-2 requirements. We have performed an
evaluation of the Funds' compliance with the requirements of subsections of
(b) and (c) of Rule 17f-2 as of August 29, 1997.
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 August 29, 1997 and for the period from
July 31, 1997 through August 29, 1997, with respect to securities reflected
in the investment accounts of The American Performance Funds.
Sincerely
/s/ D'RAY MOORE
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D'Ray Moore
Vice President