Report of Independent Accounts
To the Board of Directors of
The BNY Hamilton Funds, Inc.
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 BNY Hamilton Funds,
Inc., 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") 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 October 31, 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 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 October 31, 1999, and
with respect to agreement of security purchases and
sales, for the period from December 31, 1998 (the date
of last examination performed by other accountants)
through October 31, 1999;
We counted an inspected all securities located
in the vault of The Bank of New York (the
"Custodian"), without prior notice to management;
We obtained reconciliations between the Funds'
accounting records and the custody records as of
October 31, 1999 and verified reconciling items;
We obtained an understanding of the Custodian's
reconciliation procedures over investment postions
and the controls over these reconciliations
between the Custodian and the various depository
institution (DTC, PTC, and FRB)and the Custodian
and customer investment positions, including the
control policies over the safeguarding of physical
securities;
We agreed pending trade activity for the Funds as
of October 31, 1999 to their corresponding
subsequent statements;
We agreed to the books and records of the Funds a
sample of five purchases and four sales of
securities for the period December 31, 1998
(the date of last examination) through October
31, 1999.
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 BNY
Hamilton Funds, Inc. were in compliance with the
requirements of subsection (b) and (c) of Rule 17f-2 of
the Investment Company Act of 1940 as of October 31,
1999, with respect to securities and similar investments
reflected in the investment account 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.
ERNST & YOUNG LLP
New York, New York
January 11, 2000
Management Statement Regarding Compliance with
Certain Provision of the Investment Company Act of 1940
We, as members of management of the BNY Hamilton Funds,
Inc. (the "Funds"), are responsible for complying with
the requirements of subsection (b) and (c) of Rule
17f-2, "Custody of Invesments 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 October 31,
1999.
Based on the 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 October 31, 1999 with respect to securities
and similar investments reflected in the investments
accounts of the Funds.
BNY Hamilton Funds, Inc.
BY: /s/Laura Melmen
Laura Melmen, Vice President
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-17f-2
Certificate of Accounting of Securities and Similiar
Investment in th Custody of
Management Investment Companies
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
1. Investment Company Act File Number: 811-6654
Date examination completed: October 31, 1999
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 AE-86936-6 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: BNY Hamilton Funds, Inc.
4. Address of principal executive office {number,
street, city, state. zip code}:
3435 Stelzer Road Columbus, OH 43219
INSTRUCTIONS
The Form must be completed by invesments companies that
have custody of securities or similar invesmtents.
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 certfificate 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
