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:
811-6540 4/14/00
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 of
The Wachovia Funds and Wachovia Municipal Funds
We have examined management's assertion, included in the accompanying
"Report of Management on Compliance with Rule 17f-2 of the Investment Company
Act of 1940," that the Wachovia Funds and Wachovia Municipal Funds (the "Funds")
complied with the requirements of subsection (b) and (c) of Rule 17f-2 of the
Investment Company Act of 1940 ("the Act") as of September 30, 1999 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 based on our examination.
Our examination was conducted in accordance with attestation 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 with respect to
agreement of security and similar investments purchases and sales, for the
period from November 30, 1998 (the date of last examination) through September
30, 1999;
O Confirmation of all securities and similar investments held by institutions
in book entry form at the Depository Trust Corporation, the Bank of New
York, and the Federal Reserve Bank of Richmond; and
o Reconciliation of confirmation results as to all such securities and
investments to the books and records of the Funds and Wachovia National
Bank;
o Agreement of investment purchases and sales since our last examination from
the books and records of the Company 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 complied with the
requirements of subsection (b) and (c) of Rule 17f-2 of the Investment Company
Act of 1940 as of September 30, 1999, with respect to securities and similar
investments reflected in the investment accounts of the Funds, is fairly stated,
in all material respects.
This report is intended solely for the information and use of the board of
directors and 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.
/s/Ernst & Young LLP
Boston, Massachusetts
April 14, 2000
