AMERICAN ODYSSEY FUNDS INC /MD/
NSAR-A, EX-99, 2000-08-29
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American Odyssey Funds, Inc.
Form: N-SAR June 30, 2000
Attachment - Item 77O Transactions  effected  pursuant to Rule 10f-3
Transaction # 1: Emerging  Opportunities  Fund, purchase of Brooks Automation
If any such  transactions  were effected during the reporting period, the
following information should be furnished:
1. From whom were the securities acquired.  Needham & Co. Needham & Co. was not
an affiliated  underwriter of the Fund.
2.  Identify the  underwriting  syndicate's  members.  S.G.  Cowen was the
affiliated  underwriter  of the Fund and the  syndicate  included  various other
underwriters.
3. Terms of the transaction.  Chartwell  Investment  Partners,  a co-subadviser
to the Emerging  Opportunities  Fund,  purchased 10,000 Shares of Brooks
Automation, a company in continuous operation for 3+ years, in an initial
public  offering at the offering price of $76.00 per share on March 7, 2000. The
underwriting  selling  concession  was 3.16%.  The  percentage  of the  offering
purchased by the Emerging  Opportunities  Fund was 0.003% of the total offering.
The security  purchased was part of an issue  registered with the Securities and
Exchange  Commission  and  was  part  of  a  firm  commitment  underwriting.
4. Information or materials upon which the determination described in paragraph
(h)(3) of the rule 10f-3 was made. . The information described in item 1 through
3 above was provided to the Board of Directors at its regularly scheduled second
quarter 2000 meeting as well as information supporting the reasonableness of the
selling concession paid to certify that the purchase was made in compliance with
the Board adopted rule 10f-3  procedures.

American  Odyssey  Funds,  Inc.
Form: N-SAR June 30, 2000
Attachment - Item 77O Transactions effected pursuant to Rule 10f-3
Transaction  #  2:  Emerging   Opportunities  Fund,  purchase  of  Brooks
Automation If any such  transactions  were effected during the reporting period,
the following information should be furnished:
1. From whom were the securities acquired.  Bear Stearns.  Bear Stearns was not
an affiliated  underwriter of the Fund.
2.  Identify the  underwriting  syndicate's  members.  S.G.  Cowen was the
affiliated  underwriter  of the Fund and the  syndicate  included  various other
underwriters.
3. Terms of the transaction.  Chartwell  Investment  Partners,  a co-subadviser
to the Emerging  Opportunities  Fund,  purchased  5,000 Shares of Brooks
Automation, a company in continuous operation for 3+ years, in an initial
public  offering at the offering price of $76.00 per share on March 7, 2000. The
underwriting  selling  concession  was 3.16%.  The  percentage  of the  offering
purchased by the Emerging  Opportunities Fund was 0.0015% of the total offering.
The security  purchased was part of an issue  registered with the Securities and
Exchange  Commission  and  was  part  of  a  firm  commitment  underwriting.
4. Information or materials upon which the determination described in paragraph
(h)(3) of the rule 10f-3 was made. The information described in item 1 through 3
above was provided to the Board of Directors at its regularly  scheduled  second
quarter 2000 meeting as well as information supporting the reasonableness of the
selling concession paid to certify that the purchase was made in compliance with
the Board adopted rule 10f-3  procedures.

American  Odyssey  Funds,  Inc. Form:
N-SAR June 30, 2000
Attachment - Item 77O Transactions effected pursuant to Rule 10f-3
Transaction # 3: Emerging Opportunities Fund, purchase of Community Health
Systems If any such transactions were effected during the reporting period,  the
following  information  should be  furnished:
1. From whom were the  securities acquired.  Merrill Lynch. Merrill Lynch was
not an affiliated underwriter of the Fund.
32. Identify the  underwriting  syndicate's  members.  Smith Barney was the
affiliated  underwriter  of the Fund and the  syndicate  included  various other
underwriters.
3. Terms of the transaction.  Chartwell  Investment  Partners,  a co-subadviser
to the Emerging  Opportunities  Fund,  purchased 54,000 Shares of Community
Health Systems, a company in continuous  operation for 3+ years, in an initial
public  offering at the offering  price of $13.00 per share on June 8, 2000.
The  underwriting  selling  concession  was 3.38%.  The percentage of the
offering  purchased by the Emerging  Opportunities  Fund was 0.288% of the total
offering.  The  security  purchased  was  part of an issue  registered  with the
Securities  and  Exchange   Commission  and  was  part  of  a  firm   commitment
underwriting.
4. Information or materials upon which the determination described in paragraph
(h)(3) of the rule 10f-3 was made. The information  described in item 1 through
3 above was provided to the Board of  Directors at its  regularly scheduled
second  quarter 2000 meeting as well as  information  supporting  the
reasonableness  of the selling  concession paid to certify that the purchase was
made in  compliance  with the Board  adopted rule 10f-3  procedures.

American Odyssey Funds, Inc.
Form: N-SAR June 30, 2000
Attachment - Item 77O Transactions effected pursuant to Rule 10f-3
Transaction # 4: Long Term Bond Fund, purchase of Winstar Communications - 144A,
12.75%, due 4/15/10 If any such transactions were effected during the reporting
period,  the following  information should be furnished:
1. From whom  were the  securities  acquired.  Credit  Suisse  First Boston.
Credit  Suisse First Boston was not an  affiliated  underwriter  of the Fund.
2. Identify the underwriting syndicate's members. Salomon Smith Barney was
the affiliated  underwriter of the Fund and the syndicate included various other
underwriters.
3.  Terms of the  transaction.  Long Term Bond  Fund,  managed by Western Asset
Management  Company,  purchased $130,000 principal face of Winstar
Communications,  a company in continuous  operation for 3+ years,  in an initial
public offering at the offering price of $100.00 per unit on March 27, 2000. The
underwriting spread paid was 2.750%. The percentage of the offering purchased by
the Long  Term  Bond  Fund was  0.0002%  of the  total  offering.  The  security
purchased  was part of an issue  registered  with the  Securities  and  Exchange
Commission and was part of a firm  commitment  underwriting.
4.  Information or materials upon which the determination described in
paragraph (h)(3) of the rule 10f-3 was made. The information described in item
1 through 3 above was provided to the Board of Directors at its regularly
scheduled second quarter 2000 meeting as well as information  supporting the
reasonableness of the selling concession paid to certify that the purchase was
made in compliance  with the Board adopted rule 10f-3 procedures.

American Odyssey Funds, Inc.
Form: N-SAR June 30, 2000
Attachment - Item 77O Transactions effected pursuant to Rule 10f-3
Transaction #5: Long Term Bond Fund, purchase of 360 Networks Inc. - 144A,
13.00%, due 5/1/08 If any  such  transactions  were  effected  during  the
reporting  period,  the following  information  should be  furnished:
1. From whom were the  securities acquired.  Donaldson, Lufkin & Jenrette.
Donaldson, Lufkin & Jenrette was not an affiliated  underwriter  of the Fund.
2. Identify the  underwriting  syndicate's members. Salomon Smith Barney was
the affiliated underwriter of the Fund and the syndicate included various other
underwriters.
3. Terms of the transaction. Long Term Bond Fund, managed by Western Asset
Management  Company,  purchased $57,000 principal  face of 360 Networks  Inc.,
a company in continuous  operation for 3+ years, in an initial public offering
at the offering price of $97.590 per unit on April 20, 2000. The  underwriting
spread paid was 2.500%.  The percentage of the offering  purchased by the Long
Term Bond  Fund was  0.0001%  of the total offering.  The  security  purchased
was  part of an issue  registered  with the Securities and Exchange Commission
and  was  part  of  a  firm   commitment underwriting.
4. Information or materials upon which the determination described in paragraph
(h)(3) of the rule 10f-3 was made.  The information described in item 1 through
3 above was provided to the Board of  Directors at its  regularly scheduled
second  quarter 2000 meeting as well as  information  supporting  the
reasonableness  of the selling  concession paid to certify that the purchase was
made in  compliance  with the Board  adopted rule 10f-3  procedures.

American Odyssey Funds, Inc.
Form: N-SAR June 30, 2000
Attachment - Item 77O Transactions effected  pursuant to Rule 10f-3
Transaction # 6:  Intermediate-Term  Bond Fund, purchase of Federated,  8.5%,
due 6/1/10 If any such  transactions were effected during the reporting period,
the following  information should be furnished:
1.From whom were the securities acquired.  Credit Suisse First Boston.  Credit
Suisse First Boston was not an affiliated  underwriter  of the Fund.
2. Identify the underwriting syndicate's members. Salomon Smith Barney was the
affiliated underwriter of the Fund and the syndicate  included various other
underwriters.
3. Terms of the transaction.  Intermediate-Term  Bond Fund, managed by Travelers
Asset Management  International Company,  purchased $5,700,000 principal face of
Federated,  a company in continuous operation for 3+ years, in an initial public
offering  at the  offering  price  of  $99.803  per  unit on May 31,  2000.  The
underwriting  spread paid was 0.65%. The percentage of the offering purchased by
the  Intermediate-Term  Bond Fund was 1.63% of the total offering.  The security
purchased  was part of an issue  registered  with the  Securities  and  Exchange
Commission and was part of a firm  commitment  underwriting.
4. Information or materials upon which the determination described in paragraph
(h)(3) of the rule 10f-3 was made. The information described in item 1 through
3 above was provided to the Board of Directors at its regularly scheduled
second quarter 2000 meeting as well as information  supporting the
reasonableness of the selling concession paid to certify that the purchase was
made in compliance  with the Board adoptedrule 10f-3 procedures.

American Odyssey Funds, Inc.
Form: N-SAR June 30, 2000
Attachment - Item 77O Transactions effected pursuant to Rule 10f-3
Transaction # 7:  Intermediate-Term Bond Fund, purchase of Clear Channel Comm.,
7.875%, due 6/15/05 If any such transactions were effected during the reporting
period,  the following information should be furnished: 1. From whom were the
securities acquired. Credit Suisse First Boston. Credit Suisse First Boston was
not an affiliated  underwriter  of the Fund.
2. Identify the  underwriting syndicate's members. Salomon Smith Barney was the
affiliated underwriter of the Fund and the syndicate  included  various other
underwriters.
3. Terms of the  transaction. Intermediate-Term Bond Fund, managed by Travelers
Asset Management International Company, purchased $3,000,000 principal face of
Clear Channel Comm., a company in  continuous  operation  for 3+ years,  in an
initial  public  offering at the offering  price of $99.942 per unit on June
14, 2000.  The  underwriting  spread paid  was   0.60%.  The  percentage of the
offering   purchased   by  the Intermediate-Term  Bond  Fund was  0.40% of the
total  offering.  The  security purchased  was part of an issue  registered
with the  Securities and Exchange Commission and was part of a firm commitment
underwriting.
4.  Information or materials upon which the determination described in
paragraph (h)(3) of the rule 10f-3 was made. The information described in item
1 through 3 above was provided to the Board of Directors at its regularly
scheduled second quarter 2000 meeting as well as information  supporting the
reasonableness of the selling concession paid to certify that the purchase was
made in compliance  with the Board adoptedrule 10f-3 procedures.

American Odyssey Funds, Inc.
Form: N-SAR June 30, 2000
Attachment - Item 77O Transactions effected pursuant to Rule 10f-3 Transaction #
8:  Intermediate-Term  Bond Fund, purchase of Bank of America, 7.8%, due 2/15/10
If any  such  transactions  were  effected  during  the  reporting  period,  the
following  information  should be  furnished:
1. From whom were the  securities acquired.  Nationsbanc.  Nationsbanc  was not
an affiliated  underwriter  of the Fund.
2. Identify the underwriting syndicate's members. Salomon Smith Barney was
the affiliated  underwriter of the Fund and the syndicate included various other
underwriters.
3. Terms of the transaction.  Intermediate-Term Bond Fund, managed by Travelers
Asset  Management International Company,  purchased  $5,800,000 principal face
of Bank of America, a company in continuous operation for 3+ years, in an
initial public  offering at the offering price of $99.812 per unit on February
8, 2000. The underwriting  spread paid was 1.230%. The percentage of the
offering  purchased by the  Intermediate-Term  Bond Fund was 0.0058% of the
total offering.  The security purchased was part of an issue registered with the
Securities  and  Exchange   Commission  and  was  part  of  a  firm   commitment
underwriting.
4. Information or materials upon which the determination described in paragraph
(h)(3) of the rule 10f-3 was made. The information described in item 1 through
3 above was provided to the Board of  Directors at its  regularly scheduled
second  quarter 2000 meeting as well as  information  supporting  the
reasonableness  of the selling  concession paid to certify that the purchase was
made in  compliance  with the Board  adopted rule 10f-3  procedures.

American Odyssey Funds, Inc.
Form: N-SAR June 30, 2000
Attachment - Item 77O Transactions effected  pursuant to Rule 10f-3
Transaction # 9:  Intermediate-Term  Bond Fund, purchase of Vodaphone, 7.75%,
due 2/15/10 If any such transactions were effected during the reporting period,
the following  information should be furnished:
1. From whom were the securities acquired. Goldman Sachs & Co. Goldman Sachs &
Co. was not an affiliated  underwriter  of the Fund.
2.  Identify the underwriting syndicate's members. Salomon Smith Barney was the
affiliated underwriter of the Fund and the  syndicate  included  various other
underwriters.
3. Terms of the transaction. Intermediate-Term Bond Fund, managed by Travelers
Asset Management International Company,  purchased  $5,800,000  principal face
of Vodaphone,  a company in continuous  operation for 3+ years,  in an initial
public offering at the offering price of $99.812 per unit on February 7, 2000.
The  underwriting spread  paid  was  1.280%.  The  percentage  of the  offering
purchased  by the Intermediate-Term  Bond Fund was  0.0021% of the total
offering.  The  security purchased  was part of an issue  registered  with the
Securities  and  Exchange Commission and was part of a firm  commitment
underwriting.
4. Information or materials upon which the determination described in paragraph
(h)(3) of the rule 10f-3 was made. The information described in item 1 through
3 above was provided to the Board of Directors at its regularly scheduled
second quarter 2000 meeting as well as information  supporting the
reasonableness of the selling concession paid to certify that the purchase was
made in compliance  with the Board adopted rule 10f-3 procedures. The
information described in item 1 through 3 above was provided to the Board of
Directors at its regularly scheduled second quarter 2000 meeting as well as
information supporting the reasonableness of the selling concession paid to
certify that the purchase was made in compliance with the Board adopted rule
10f-3 procedures.





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