Exhibit to Accompany
Item 77J b
Form N-SAR
ICAP Funds, Inc. the Fund
According to the provisions of Statement of Position
93-2 SOP 93 - 2 Determination, Disclosure and
Financial Statement Presentation of Income, Capital
Gain and Return of Capital Distributions by
Investment
Companies, the Fund is required to report the
accumulated net investment income loss and
accumulated net capital gain loss accounts to
approximate amounts available for future
distributions on a tax basis or to offset future
realized capital gains. Accordingly, at June 30,
2000, reclassifications were recorded to
increase undistributed net investment income by $170,
$170 and $487; decrease accumulated net realized loss
on investments by $0, $0, and $487; and decrease
paid-in-capital in excess of par by $170, $170, and
$0 for the Discretionary Equity, Equity and Select
Equity Portfolios, respectively.
This reclassification has no impact on the net asset
value of the Fund and is designed to present the
Fund's capital accounts on a tax basis.
