UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, DC 20549
FORM N-17f-2
Certificate of Accounting or Securities and Similar
Investments in the Custody of
Management Investment Companies
Pursuant to Rule 17f-2 [17 CRF 270.17f-2]
1. Investment Company Act File Date examination
Number: completed:
811-8738 09/22/00
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 MI 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: Whitehall Funds Trust
4. Address of principal executive office: (number, street,
city, state, zip code) 4400 Computer Drive,
Westboro, MA 01581
INSTRUCTIONS
The 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, examine 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 Commissions'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
Independent Accountant's Report
To the Board of Trustees
Whitehall Funds Trust
We have examined management's assertion about
Whitehall Funds Trust's (comprising,
respectively, the Whitehall Income Fund, the
Whitehall Growth Fund, the Whitehall Money
Market Fund and the Whitehall Growth and
Income Fund) (the "Company") compliance with
the requirements of subsections (b) and (c)
of Rule 17f-2 of the Investment Company Act
of 1940 (the "Act") as of July 31, 2000,
with respect to securities and similar
investments reflected in the investment
account of the Company, 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 Company'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 Company'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 July 31,
2000, and with respect to agreement of
security and similar investments purchases
and sales, for the period from November 30,
1999 (the date of last examination) through
July 31, 2000:
Count and inspection of all securities and
similar investments located in the vault of
IBJ Whitehall Bank & Trust Company in New
York, without prior notice to management;
Confirmation of all securities and similar
investments held by institutions in book
entry form (i.e., the Bank of New York);
Reconciliation of confirmation results as
to all such securities and investments to
the books and records of the Company and
of IBJ Whitehall Bank & Trust Company;
Confirmation of all repurchase agreements,
if any, with brokers/banks and agreement
of underlying collateral with of IBJ
Whitehall Bank & Trust Company's records;
Agreement of five security and/or
investment purchases and five security
and/or investment sales or maturities
since our last examination from the books
and records of the Company 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 Company's compliance
with specified requirements.
In our opinion, management's assertion that
IBJ Funds Trust was in compliance with the
requirements of subsections (b) and (c) of
Rule 17f-2 of the Investment Company Act of
1940 as of July 31, 2000, with respect to
securities and similar investments reflected
in the investment account of the Company is
fairly stated, in all material respects.
This report is intended solely for the
information and use of management of IBJ
Funds Trust and the Securities and Exchange
Commission and should not be used for any
other purpose.
/s/ERNST & YOUNG LLP
September 22, 2000
