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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION /-----------------------------/
Washington, D.C. 20549 / OMB APPROVAL /
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FORM N-17f-2 /OMB Number: 3235-0360/
/Expires: July 31, 1994/
/Estimated average burden /
/hours per response ......0.05/
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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]
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1. Investment Company Act File Number: Date examination completed:
811-6526 January 31, 2000
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2. State identification Number:
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<S> <C> <C> <C> <C> <C>
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:
The Coventry Group: Boston Balanced Fund, Walden Social Balanced Fund and Walden Social Equity Fund
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4. Address of principal executive office (number, street, city, state, zip code):
3435 Stelzer Road, Columbus, Ohio 43219
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INSTRUCTIONS
This Form must be completed by 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 of administrator(s),
if applicable.
THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT
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Management Statement Regarding Compliance with Certain Provisions of the
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Investment Company Act of 1940
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We, as members of management of the Boston Balanced Fund, the Walden Social
Balanced Fund, and the Walden Social Equity Fund (collectively, 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
those requirements. We have performed an evaluation of the Funds' compliance
with the requirements of subsections (b) and (c) of Rule 17f-2 as of January 31,
2000 and from November 30, 1999 through January 31, 2000.
Based on this evaluation, we assert that the Funds were in compliance with those
requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company
Act of 1940 as of January 31, 2000, and from November 30, 1999 through January
31, 2000, with respect to securities reflected in the investment accounts of the
Funds.
The Boston Balanced Fund
The Walden Social Balanced Fund
The Walden Social Equity Fund
By:
/s/ Sue A. Walters
May 30, 2000
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Report of Independent Public Accountants
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To the Board of Trustees of the Boston Balanced Fund, the Walden Social Balanced
Fund, and the Walden Social Equity Fund:
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 Boston Balanced Fund, the Walden Social Balanced Fund, and
the Walden Social Equity Fund (collectively, the "Funds") complied with the
requirements of subsections (b) and (c) of Rule 17f-2 under the Investment
Company Act of 1940 (the "Act") as of January 31, 2000. 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 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 January 31, 2000, and with respect to agreement of
security purchases and sales, for the period from November 30, 1999 (date of our
last examination) through January 31, 2000, without prior notice to management:
. Confirmation of all securities held by institutions in book entry form (The
Bank of New York);
. Reconciliation of all such securities to the books and records of the Funds
and United States Trust Company of Boston, the custodian;
. Confirmation of all certificates of deposit and money markets with
brokers/banks and transfer agents and agreement with United States Trust
Company of Boston records; and
. Agreement of two (2) security purchases and two (2) security sales or
maturities for each Fund identified above since our last report 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 complied with the
requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company
Act of 1940 as of January 31, 2000, with respect to securities reflected in the
investment accounts 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 and the
Board of Trustees of the Funds and the Securities and Exchange Commission and it
is not intended to be and should not be used by anyone other than these
specified parties.
/s/ ARTHUR ANDERSEN LLP
Cincinnati, Ohio
May 30, 2000
