[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: July 31, 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
July 31, 1997 and for the period from May 30, 1997 through July 31, 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 July 31, 1997 and for the period
from May 30, 1997 (the date of our last examination) through July 31, 1997,
with respect to securities transactions, without prior notice to
management:
1. Confirmation of all securities held as of July 31, 1997 by
subcustodians;
2. Verification of all securities purchased/sold but not received/delivered
and securities in transit as of July 31, 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 July 31, 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 July 31, 1997 and for the period from May 30, 1997 through
July 31, 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
August 15, 1997
August 15, 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 July 31, 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 July 31, 1997 and for the period from
May 30, 1997 through July 31, 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
