U.S. SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM N-17F-2
CERTIFICATE OF ACCOUNTING OF SECURITIES AND SIMILAR INVESTMENTS IN THE CUSTODY
OF MANAGEMENT INVESTMENT COMPANIES
Pursuant to Rule 17f-2 [17 CFR 270, 17f-2]
1. Investment Company Act File Number: Date examination completed:
811-6504 9/13/99
2. State Identification Number:
AL AK AZ AR CA CO
CT DE DC FL GA HI
ID IL IN IA KS KY
LA ME MD MA MI MN
MS MO MT NE NV NH
NJ NM NY NC ND OH
OK OR PA RI SC SD
TN TX UT VT VA WA
WV WI WY PUERTO RICO
Other (specify):
3. Exact name of investment company as specified in registration statement:
THE WACHOVIA FUNDS
4. Address of principal executive office:
(number, street, city, state, zip code)
FEDERATED INVESTORS TOWER, PITTSBURGH, PA 15222-3379
INSTRUCTIONS
This Form must be completed by the investment companies that have custody
of securities or similar investments.
Investment Company
1. All items must be completed by the investment company.
2. Give this Form to the independent public accountant who, in compliance with
Rule 17f-2 under the Act and applicable state law, examines securities and
similar investments in the custody of the investment company.
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
Note: The estimated average burden hours are made solely for purposes of
the Paperwork Reduction Act, and are not derived from a comprehensive or even a
representative survey or study of the costs of SEC rules and forms. Direct any
comments concerning the accuracy of the estimated average burden hours for
compliance with SEC rules and forms to Kenneth A. Fogash, Deputy Executive
Director, U.S. Securities and Exchange Commission, 450 Fifth Street, N.W.,
Washington, D.C. 20549 and Gary Waxman, Clearance Officer, Office of Management
and Budget, Room 3208 New Executive Office Building, Washington, D.C. 20503.
Report of Independent Accountants
Board of Directors and Trustees
Wachovia Funds and Wachovia Municipal Funds
We have examined management's assertion, included in the accompanying
Management Statement Regarding Compliance with Certain Provisions of the
Investment Company Act of 1940, that the Wachovia Funds and Wachovia Municipal
Funds (the "Funds") were in compliance with the requirements of subsection (b)
and (c) of Rule 17f-2 of the Investment Company Act of 1940 ("the Act") as of
November 30, 1998 with respect to securities and similar investments reflected
in the investment accounts of the Funds. 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 November 30, 1998;
O Confirmation of all securities and similar investments held by institutions
in book entry form at the Depository Trust Corporation and the Federal
Reserve Bank of Richmond;
o Reconciliation of confirmation results as to all such securities and
investments to the books and records of the Funds and Wachovia National
Bank;
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 subsection (b) and (c) of Rule 17f-2 of the Investment
Company Act of 1940 as of November 30, 1998, with respect to securities and
similar investments reflected in the investment accounts of the Funds, are
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 and
should not be used by anyone other than these specified parties.
/s/Ernst & Young LLP
Pittsburgh, Pennsylvania
September 13, 1999
