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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM N-17f-1 -----------------------------------
OMB APPROVAL
Certificate of Accounting of Securities and Similar -----------------------------------
Investments of a Management Investment Company OMB Number: 3235-0359
in the Custody of Members of Expires: July 31, 1991
National Securities Exchanges Estimated average burden
hours per response . . . .0.05
Pursuant to Rule 17f-1 [17 CFR 270.17f-1]
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<S> <C> <C> <C> <C> <C> <C>
1. Investment Company Act File Number: Date examination completed:
801 - 811-1920 JUNE 30, 1999
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2. State identification Number:
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AL AK AZ AR CA CO
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CT DE DC FL GA HI
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ID IL IN IA KS KY
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LA ME MD MA MI MN
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MS MO MT NE NV NH
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NJ NM NY 108960 NC ND OH
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OK OR PA RI SC SD
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TN TX UT VT VA WA
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WV WI WY PUERTO RICO
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Other (specify):
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3. Exact name of investment company as specified in registration statement:
Stralem Fund
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4. Name under which business is conducted, if different from above:
N/A
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5. Address of principal place of business (number, street, city, state, zip code):
405 Park Avenue, New York, NY 10022
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INSTRUCTIONS
This Form must be completed by investment companies that place or maintain
securities or similar investments in the custody of a company that is a member
of a national securities exchange.
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-1 under the Act and applicable state law, examines securities and
similar investments in the custody of a company that is a member of a
national securities exchange.
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-1 under the Act and applicable state law. File the
original and one copy with the Securities and Exchange Commission'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
Note: The estimated average burden hours are made solely for purposes of the
Paperwork Reduction Act, and are not derived from a comprehensive or
even a representative survey or study of the costs of SEC rules and
forms. Direct any comments concerning the accuracy of the estimated
average burden hours for compliance with SEC rules and forms to Kenneth
A. Fogash, Deputy Executive Director, U.S. Securities and Exchange
Commission, 450 Fifth Street, N.W., Washington, D.C., 20549 and Gary
Waxman, Clearance Officer.
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STRALEM FUND
405 PARK AVENUE, NEW YORK, NY 10022-4405
TEL: (212)888-8123
FAX: (212)888-8152
MANAGEMENT STATEMENT REGARDING COMPLIANCE WITH
CERTAIN PROVISIONS OF THE INVESTMENT COMPANY ACT OF 1940
We, as members of management of Stralem Fund (The "Company"), are
responsible for complying with the requirements of subsection (b) of Rule 17f-1
"Custody of Securities with Members of National Securities Exchanges" of the
Investment Company Act of 1940. We are also responsible for establishing and
maintaining effective internal controls over compliance with those requirements.
We have performed an evaluation of the Company's compliance with the
requirements of subsection (b) of Rule 17f-1 as of June 30, 1999. Based on this
evaluation, we assert that the Company was in compliance with the requirements
of subsections (b) of Rule 17f-1 of the Investment Company Act of 1940 as of
June 30, 1999 and from January 1, 1999 through June 30, 1999, with respect to
securities reflected in the investment account of the Company.
Stralem Fund
By: /s/ Hirschel B. Abelson
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Hirschel B. Abelson, Treasurer
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[LETTERHEAD]
INDEPENDENT AUDITORS' REPORT
To the Board of Directors of
Stralem Fund
and
The Securities Exchange Commission
We have examined management's assertion about Stralem Fund's (the "Company's")
compliance with the requirements of Subsection (b)(1) and (b)(6) of rule 17f-1
under the Investment Company Act of 1940 (the "Act") as of June 30, 1999,
included in the accompanying Management Statement Regarding Compliance with
Certain Provisions of the Act. 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 June 30, 1999 and with respect to agreement of security
purchases and sales, for the period January 1, 1999 through June 30, 1999.
- - Confirmation of all securities with the custodian broker, Schroders,
located at 787 Seventh Avenue, New York, NY 10019.
- - Reconciliation of all such securities to the books and records of the
Company and the Custodian.
- - Agreement of 5 securities purchased and 4 securities sold from the books
and records of the Company to the 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 the Company was in compliance with
the requirements of Subsection (b)(1) and (b)(6) of Rule 17f-1 of the Act of
1940 as of June 30, 1999 with respect to securities 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 the
Company and the Securities Exchange Commission and should not be used for any
other purpose.
/s/ Richard A. Eisner & Company, LLP
New York, New York
August 4, 1999
