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SECURITIES AND EXCHANGE COMMISSION ---------------------------
WASHINGTON, D.C. 20549 OMB Approval
FORM N-17f-2 ---------------------------
OMB Number: 3235-0360
Certificate of Accounting of Securities and Similar Expires: July 31, 1991
Investments in the Custody of Estimated average burden
Management Investment Companies hours per response.... 0.05
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
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1. Investment Company Act File Number:
811-6654
Date examination completed: December 31, 1998
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2. State identification Number:
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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 AE-86936-6 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:
BNY Hamilton Funds, Inc.
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4. Name under which business is conducted, if different from above:
N/A
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5. Address of principal place of business (number, street, city, state,
zip code):
3435 Stelzer Road, Columbus, OH 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 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 St.,
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.
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KPMG
757 Third Avenue Telephone 212 758 9700
New York, NY 10017 Fax 212 872 3001
Independent Accountants' Report
The Securities and Exchange Commission
The Board of Directors of
The BNY Hamilton Funds, Inc.
We have examined management's assertion about the BNY Hamilton Funds', including
the Equity Income Fund, Intermediate Government Fund, Intermediate New York
Tax-Exempt Fund, Intermediate Tax-Exempt Fund, Intermediate Investment Grade
Fund, Large Cap Growth Fund, Money Fund, Small Cap Growth Fund, and Treasury
Money Fund (the "Funds"), compliance with the requirements of subsection (b) and
(c) of Rule 17f-2 under the Investment Company Act of 1940 as of December 31,
1998, included in Management's Statement Regarding Compliance with Certain
Provisions of the Investment Company Act of 1940. 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
examinations.
Our examinations were 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 December 31, 1998 and, with respect to security purchases and
sales, for the period from November 13, 1998 (the date of our last examination)
through December 31, 1998:
o We counted and inspected all securities located in the vault of The Bank of
New York (the "Custodian");
o We obtained reconciliations between the Funds' accounting records and the
custody records as of December 31, 1998 and verified reconciling items;
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o We and other auditors reviewed the Custodian's reconciliation procedures
over investment positions and the controls over these reconciliations
between the Custodian and the various depository institutions (DTC, PTC,
and FRB) and the Custodian and customer investment positions. Furthermore,
we and other auditors reviewed the control policies over the safeguarding
of physical securities;
o We agreed pending trade activity for the Funds as of December 31, 1998 to
their corresponding subsequent statements;
o We agreed to the books and records of the Funds a sample of purchases and
sales of securities for the period November 13, 1998 (the date of our last
examination) through December 31, 1998, noting that they had been properly
recorded.
We believe that our examinations provide a reasonable basis for our opinion. Our
examinations do not provide a legal determination on the Funds' compliance with
the specified requirements.
In our opinion, management's assertion that the BNY Hamilton 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 December 31, 1998, with respect to
securities 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 management of the
BNY Hamilton Funds, Inc., and the Securities and Exchange Commission and should
not be used for any other purpose.
KPMG LLP
January 4, 1999
