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 10/09/00
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 August 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 August 31,
2000, and with respect to agreement of
security and similar investments purchases
and sales, for the period from July 31,
2000 (the date of last examination) through
August 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 August 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.
ERNST & YOUNG LLP
October 9, 2000
Management Statement Regarding Compliance with
Certain Provisions
of the Investment Company Act of 1940
We, as members of management of IBJ Whitehall
Bank & Trust Company, custodian and investment
advisor for IBJ Funds Trust (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 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 August 31, 2000.
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 August 31,
2000, with respect to securities and similar
investments reflected in the investment account
of the Company.
By:
/s/
Joseph E. Breslin,President
Whitehall Funds Trust
Senior Vice President
IBJ Whitehall Bank & Trust Company
