Deloitte & Touche LLP
2500 One PPG Place
Pittsburgh, Pennsylvania 15222-5401
412-338-7200
Fax 412-338-7380
Great Plains Funds
c/o Federated Services Company
Federated Investors Tower
Pittsburgh, PA 15222-3779
To the Board of Trustees of Great Plains Funds:
Portfolios of Great Plains Funds File No.
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Equity Fund 811-8281
Intermediate Bond Fund 811-8281
Tax-Free Bond Fund 811-8281
Premier Fund 811-8281
International Equity Fund 811-8281
We have examined management's assertion about the Great Plains Funds' (the
"Funds") compliance with the requirements of subsections (b) and (c) of Rule
17f-2 under the Investment Company Act of 1940 ("the Act") as of November 10,
1999 included in the accompanying Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940. Management is
responsible for the Funds' compliance with those requirements. Our
responsibility is to express an opinion on management's assertion about the
Funds' 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 Funds' 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, without prior notice to management, as of November 10, 1999, and with
respect to agreement of security purchases and sales, for the period from August
23, 1999 (the date of our last examination) through November 10, 1999:
o Confirmation of all securities held by Northern Trust, located in Chicago,
IL, with such securities held for the account of National Bank of Commerce
Trust and Savings Association ("NBC"), the Custodian, located in Lincoln,
NB;
o Confirmation of all securities hypothecated, pledged, placed in escrow, or
out for transfer with brokers, pledgees and/or transfer agents;
o Reconciliation of all such securities to the books and records of the Funds
and the Custodian; and
o Agreement of a total of 25 security purchases and a total of 25 security
sales or maturities across all Funds since our last report from the books
and records of the Funds 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 Funds' compliance with
specified requirements.
In our opinion, management's assertion that the Great Plains Funds were in
compliance with the requirements of subsections (b) and (c) of Rule 17f-2 of the
Investment Company Act of 1940 as of November 10, 1999 with respect to
securities reflected in the investment account of the Funds is fairly stated, in
all material respects.
This report is intended solely for the information and use of management of the
Great Plains 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.
/s/ DELOITTE & TOUCHE LLP
April 5, 2000
<PAGE>
Management Statement Regarding Compliance
With Certain Provisions of the
Investment Company Act of 1940
April 5, 2000
Deloitte & Touche LLP
Attn: Kristina Alexander
2500 One PPG Place
Pittsburgh, PA 15222
In connection with your attestation engagement as of November 10, 1999 relating
to the Great Plains Funds compliance with Securities and Exchange Commission
Rule 17f-2, we confirm, to the best of our knowledge and belief, the following
representations made to you during your procedures:
1. We, as members of management of National Bank of Commerce Trust and Savings
Association ("NBC"), the Custodian of the Great Plains Funds (the "Funds"),
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.
2. We are also responsible for establishing and maintaining effective internal
controls over compliance with those requirements.
3. The Funds were in compliance with the requirements of subsections (b) and
(c) of Rule 17f-2 of the Investment Company Act of 1940 as of November 10,
1999 and from August 23, 1999 through November 10, 1999, with respect to
securities reflected in the investment account of the Great Plains Funds.
4. We have no knowledge of significant matters that are contrary to your
findings.
/s/ Steven R. Caswell
Steven R. Caswell
Senior Vice President
