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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: Date examination completed:
811-6114 8/31/99
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2. State identification Number:
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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 representation statement:
American Performance Funds
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5. Address of principal executive office (number, street, city, state, zip code):
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.
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)
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AMERICAN PERFORMANCE FUNDS
3435 Stelzer Road, Suite 1000
Columbus, Ohio 43219-8001
October 15, 1999
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 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 August 31, 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 August 31, 1999 and for the period from June 30, 1999 (date of
the last examination) through August 31, 1999, with respect to securities
reflected in the investment accounts of the Funds.
Sincerely,
/s/ WALTER B. GRIMM
Walter B. Grimm
Chairman
American Performance Funds
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To the Board of Trustees 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 31, 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 August 31, 1999, and with respect to agreement of security
purchases and sales, for the period from June 30, 1999 (the date of our last
examination) through August 31, 1999:
1. Confirmation of all securities held by Bank of Oklahoma, N.A. (Bank of
Oklahoma) in book entry form;
2. Verification of all securities purchased/sold but not received/delivered
and securities in transit 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 Bank of Oklahoma;
4. Confirmation of all repurchase agreements with brokers/banks and
agreement of underlying collateral with the Bank of Oklahoma records;
and
5. Agreement of four selected security purchases, sales or maturities since
our last report from the books and records of the Funds to broker
confirmations or trade tickets.
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 requirements of subsections (b) and (c) of Rule 17f-2 of the Investment
Company Act of 1940 as of August 31, 1999, with respect to securities reflected
in the investment account of the Funds is fairly stated, in all material
respects.
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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 LLP
Columbus, Ohio
October 15, 1999
