<PAGE> 1
UNITED STATES
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]
----------------------------
OMB APPROVAL
----------------------------
OMB Number: 3235-0360
Expires: July 31, 1994
Estimated average burden
hours per response......0.05
----------------------------
- ------------------------------------------------------------------------------
1. Investment Company Act File Number: Date examination completed:
811-06580 April 30, 1998
- ------------------------------------------------------------------------------
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:
SOUTHTRUST VULCAN FUNDS
- ------------------------------------------------------------------------------
- ------------------------------------------------------------------------------
4. Address of principal executive office (number, street, city, state, zip
code):
Federated Investors Tower, Pittsburgh, PA 15222-3779
- ------------------------------------------------------------------------------
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
SEC 2198(11-91)
<PAGE> 2
REPORT OF INDEPENDENT PUBLIC ACCOUNTANTS
To the Board of Trustees of
the Vulcan Funds:
We have examined management's assertion about the VULCAN FUNDS' (the "Funds")
compliance with the requirements of subsections (b) and (c) of Rule 17f-2 under
the Investment Company Act of 1940 (the "Act") as of April 30, 1998 included in
the accompanying Management Statement Regarding Compliance with Certain
Provisions of the Investment Company Act of 1940. The Vulcan Funds include the
Bond Fund, Treasury Obligations Money Market Fund, Stock Fund, and Income Fund.
Management is responsible for the Funds' compliance with the requirements of the
Act. 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 April 30, 1998 and for the period from March 31, 1998 (the date
of the last examination) through April 30, 1998, with respect to agreement of
security purchases and sales:
- Confirmation of all securities held by institutions in book entry
form (the Federal Reserve Bank of Birmingham and The Depository
Trust Company);
- Confirmation of all securities hypothecated, pledged, placed in
escrow, or out for transfer with brokers, pledgees, transfer
agents, and/or remarketing agents;
- Reconciliation of all such securities to the books and records of
the Funds and SouthTrust Bank, N.A., the Custodian;
- Confirmation of all repurchase agreements with brokers/banks and
agreement of underlying collateral with Custodian records; and
- Agreement of two (2) security purchases and two (2) security sales
or maturities for each fund identified above (since the date of
the 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.
<PAGE> 3
-2-
In our opinion, management's assertion that the Vulcan 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 April 30, 1998 is fairly stated, in all material
respects.
This report is intended solely for the information and use of management of the
Vulcan Funds and the Securities and Exchange Commission and should not be used
for any other purpose.
Birmingham, Alabama
May 13, 1998
<PAGE> 4
MANAGEMENT STATEMENT REGARDING COMPLIANCE WITH
CERTAIN PROVISIONS OF THE INVESTMENT COMPANY ACT OF 1940
We, as members of the Vulcan Funds (the "Funds"), the investment company, and
SouthTrust Bank, N.A., the custodian, are responsible for complying with the
requirement 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 an effective
internal control structure over compliance with those requirements. We have
performed an evaluation of the Fund's compliance with the requirements of
subsection (b) and (c) of Rule 17f-2 as of April 30, 1998 and for the period
from March 31, 1998 (the date of the last examination) through April 30, 1998.
Based on this evaluation, we assert that the Funds were in compliance with those
provisions of Rule 17f-2 of the Investment Company Act of 1940 as of April 30,
1998 and the period from March 31, 1998 (the date of the last examination)
through April 30, 1998 with respect to securities reflected in the investment
account of the Funds.
Vulcan Funds SouthTrust Bank, N.A.
By:/s/ C. Christine Thomson By:/s/ Roger L. Brown
------------------------------------ --------------------------------
C. Christine Thomson Roger L. Brown
Vice President & Assistant Treasurer Senior Vice President
May 13, 1998
