Board of Directors of Kenilworth Fund, Inc.
and the Securities and Exchange Commission
We have examined management's assertion about the Kenilworth
Fund, Inc.'s (the "Company") compliance with certain rules under
the Investment Company Act of 1940 (the "Act") as of December 31,
1999, and during the period December 31, 1998 (the date of the
last report on Management's Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940) through
December 31, 1999, included in the accompanying Management
Statement Regarding Compliance with Certain Provisions of the
Investment Company Act of 1940. Management is responsible for
the Company's compliance with those requirements. Our
responsibility is to express an opinion on Management's assertion
about the Fund's 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 Fund's 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, 1999, with respect to securities of the
Kenilworth Fund, Inc. and similar investment purchases and sales:
Count and inspection of all securities located in the vault of
the National Safe Deposit Company, One First National Plaza,
Chicago, Illinois 60603.
Confirmation of all securities purchased but not received with
brokers.
Reconciliation of all such securities to the books and records of
the Company.
We believe that our examination provides a reasonable basis for
our opinion. Our examination does not provide a legal
determination on the Company's compliance with specified
requirements.
In our opinion, management's assertion that the Kenilworth Fund,
Inc. was in compliance with certain provisions of Rule 17f-2 of
the Investment Company Act of 1940 as of December 31, 1999, is
fairly stated in all material respects.
This report is intended solely for the information and use of
management of the Kenilworth Fund,Inc. and the Securities and
Exchange Commission and should not be used for any other purpose.
/s/ Grant Thornton LLP
Chicago, Illinois
January 7, 2000
<PAGE>
Management Statement Regarding Compliance with Certain Provisions
of the Investment Company Act of 1940
We, as members of management of the Kenilworth Fund, Inc. (the
"Company"), are responsible for complying with the requirements
of subsections (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 internal controls over compliance with
those requirements. We have performed an evaluation of the
Company's compliance with the requirements of subsections (b) and
(c) of Rule 17f-2 as of December 31, 1999 and from December 31,
1998 through December 31, 1999.
Based on this evaluation, we assert that the Company was in
compliance with the requirements of subsections (b) and (c) of
Rule 17f-2 of the Investment Company Act of 1940 as of December
31, 1999 and from December 31, 1998 through December 31, 1999,
with respect to securities reflected in the investment account of
the Company.
Kenilworth Fund, Inc.
By:
/s/ Savitri P. Pai
General Counsel
Kenilworth Fund, Inc.
<PAGE>
<PAGE>
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549 OMB APPROVAL
OMB Number: 3235-0360
FORM N-17f-2 Expires June 30, 1997
Estimated average burden
hours per response..0.05
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]
1. Investment Company Act File Number: 811-7620
Date examination completed: December 31, 1999
2. State identification Number:
CA: 5/6/97 FL: 048290 IL:9325975 TX: C5286000000
3. Exact name of investment company as specified in registration
statement:
KENILWORTH FUND, INC.
4. Address of principal executive office (number, street, city,
state, zip code):
One First National Plaza, Suite 2594, Chicago, IL 60603
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
SEC 2198 (8-95)
