To The Shareholders and Board of Directors
First Omaha Funds, Inc.:
In planning and performing our audit of the financial
statements of First Omaha Funds, Inc. (comprised
respectively, of the U. S. Government Money Market
Fund, Growth Fund, Short/Intermediate Fixed Income
Fund, Fixed Income Fund, Equity Fund, Small Cap Value
Fund, and Balanced Fund, collectively "the Funds")
for the year ended March 31, 2000, we considered its
internal control, including control activities for
safeguarding securities, in order to determine our
auditing procedures for the purpose of expressing our
opinion on the financial statements and to comply
with the requirements of Form N-SAR, not to provide
assurance on the internal control.
The management of the Funds is responsible for
establishing and maintaining internal control. In
fulfilling this responsibility, estimates and
judgments by management are required to assess the
expected benefits and related costs of controls.
Generally, controls that are relevant to an audit
pertain to the entity's objective of preparing
financial statements for external purposes that are
fairly presented in conformity with generally
accepted accounting principles. Those controls
include the safeguarding of assets against
unauthorized acquisition, use or disposition.
Because of inherent limitations in internal control,
errors or fraud may occur and may not be detected.
Also, projection of any evaluation of internal
control to future periods is subject to the risk that
it may become inadequate because of changes in
conditions or that the effectiveness of the design
and operation may deteriorate.
Our consideration of internal control would not
necessarily disclose all matters in internal control
that might be material weaknesses under standards
established by the American Institute of Certified
Public Accountants. A material weakness is a
condition in which the design or operation of one or
more of the internal control components does not
reduce to a relatively low level the risk that
misstatements caused by error or fraud in amounts
that would be material in relation to the financial
statements being audited may occur and not be
detected within a timely period by employees in the
normal course of performing their assigned functions.
However, we noted no matters involving internal
control and its operation, including procedures for
safeguarding securities, that we consider to be
material weaknesses as defined above as of March 31,
2000.
This report is intended solely for the information
and use of the Board of Directors, management of the
Funds and the Securities and Exchange Commission and
is not intended to be and should not be used by
anyone other than these specified parties.
KPMG LLC
April 14, 2000
