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Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940
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We, as members of management of Brenton Mutual Funds of The Coventry Group (the
"Funds"), are responsible for complying with the requirements of subsection (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 controls over compliance
with those requirements. We have performed an evaluation of the Funds'
compliance with the requirements of subsection (b) and (c) of Rule 17f-2 as of
November 30, 1999.
Based on this evaluation, we assert 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, 1999 with respect to securities and similar
investments reflected in the investment account of the Funds.
Brenton Mutual Funds
By:
/s/ Walter B. Grimm
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Walter Grimm, President
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Report of Independent Accountants
To the Board of Trustees of
Brenton Mutual Funds of The Coventry Group
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 Brenton Mutual 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, 1999 with respect to securities and
similar investments reflected in the investment account 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 without prior notice to management. 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, 1999, and with respect to agreement of security and similar
investments purchases and sales, for the period from September 30, 1999 (the
date of last examination) through November 30, 1999;
o Confirmation of all securities and similar investments held by
institutions in book entry form with the Federal Reserve Bank of Chicago,
The Northern Trust Company, and Goldman Sachs;
o Reconciliation of confirmation results as to all such securities and
investments to the books and records of the Funds and the Custodian;
o Agreement of three security and/or investment purchases and three security
and/or investment sales or maturities since our last examination 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 Brenton Mutual 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, 1999, with respect to
securities and similar investments 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
Brenton Mutual 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.
ERNST & YOUNG LLP
Columbus, Ohio
January 17, 2000
