e40v17f2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-17f-2
Certificate of Accounting of Securities and Similar
Investments in the Custody of
Management Investment Companies
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
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1.
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Investment Company Act File Number:
811-07687, 811-03313, 811-05309, 811-07680, 811-21193, 811-07678, 811-05642, 811-06404, 811-06640, 811-07444, 811-07838, 811-21824
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Date examination completed:
May 27, 2010 |
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2.
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State identification Number: |
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HI |
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IL |
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IN |
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MN |
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NE |
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NH |
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NJ |
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NM |
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NY |
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NC |
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ND |
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OH |
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OK |
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OR |
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PA |
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RI |
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TN |
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UT |
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WA |
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WV |
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WI |
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WY |
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PUERTO RICO |
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Other (specify): |
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3.
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Exact name of investment company as specified in registration statement: |
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First American Strategy Funds, Inc., First American Funds, Inc., First
American Investment Funds, Inc., Minnesota Municipal Income Portfolio Inc., First American Minnesota Municipal Income Fund II, Inc., American Municipal Income Portfolio Inc., American Income Fund, Inc.,
American Strategic Income Portfolio Inc., American Strategic Income Portfolio Inc. II, American Strategic Income Portfolio Inc. III, American Select Portfolio Inc., Mount Vernon Securities Lending Trust |
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4.
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Address of principal executive office (number, street, city, state, zip code): |
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800 Nicollet Mall |
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Minneapolis, MN 55402 |
INSTRUCTIONS
This Form must be completed by investment companies that have custody of securities or similar
investments.
Investment Company
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1.
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All items must be completed by the investment company. |
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2.
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Give this Form to the independent public accountant who, in compliance
with Rule 17f-2 under the Act and applicable state law, examines
securities and similar investments in the custody of the investment
company. |
Accountant
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3.
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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 principal office in Washington,
D.C., one copy with the regional office for the region in which the
investment companys principal business operations are conducted, and
one copy with the appropriate state administrator(s), if applicable. |
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
May 27, 2010
I, as a member of management of the American Income Fund, Inc. (referred to as the fund), am
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. I am also responsible for establishing and maintaining effective internal controls over
compliance with those requirements. I have performed an evaluation of the funds compliance with
the requirements of subsections (b) and (c) of rule 17f-2 as of February 26, 2010, and from June
26, 2009 through February 26, 2010.
Based on this evaluation, I assert that the fund was in compliance with the requirements of
subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 as of February 26,
2010, and from June 26, 2009 through February 26, 2010, with respect to securities reflected in the
investment accounts of the fund.
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By: |
/s/ Charles D. Gariboldi, Jr.
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Charles D. Gariboldi, Jr. |
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Treasurer
American Income Fund, Inc. |
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Report of Independent Registered Public Accounting Firm
The Board of Directors
American Income Fund, Inc.
We have examined managements assertion, included in the accompanying Management Statement
Regarding Compliance With Certain Provisions of the Investment Company Act of 1940, that the
American Income Fund, Inc. (referred to as the fund) complied with the requirements of subsections
(b) and (c) of rule 17f-2 of the Investment Company Act of 1940 (the Act) as of February 26, 2010.
Management is responsible for the funds compliance with those requirements. Our responsibility is
to express an opinion on managements assertion about the funds compliance based on our
examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting
Oversight Board (United States) 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 as of February 26, 2010, and with respect to agreement of security purchases and sales,
for the period from June 26, 2009 (the date of our last examination) through February 26, 2010:
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Confirmation of all securities held by institutions in book entry form (Bank of New
York, Depository Trust Company, and Federal Reserve Bank of Boston); |
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Confirmation of all securities hypothecated, pledged, placed in escrow, or out for
transfer with brokers, pledgees, or transfer agents; |
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Reconciliation of all such securities to the books and records of the fund and U.S.
Bank National Association (the Custodian); |
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Confirmation of all reverse repurchase agreements with brokers/banks and agreement of
underlying collateral with the Custodians records; and |
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Review of one security sale or maturity since our last report from the books and
records of the fund, noting it has been accurately reported and subsequently settled. |
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.
1
In our opinion, managements assertion that the fund complied with the requirements of subsections
(b) and (c) of rule 17f-2 of the Act as of February 26, 2010, with respect to securities reflected
in the investment accounts of the fund, is fairly stated, in all material respects.
This report is intended solely for the information and use of management and the Board of Directors
of the fund and the Securities and Exchange Commission and is not intended to be and should not be
used by anyone other than these specified parties.
//Ernst & Young LLP
Minneapolis, Minnesota
May 27, 2010
2
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
May 27, 2010
I, as a member of management of the American Municipal Income Portfolio Inc. (referred to as the
fund), am 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. I am also responsible for establishing and maintaining effective internal controls
over compliance with those requirements. I have performed an evaluation of the funds compliance
with the requirements of subsections (b) and (c) of rule 17f-2 as of February 26, 2010, and from
June 26, 2009 through February 26, 2010.
Based on this evaluation, I assert that the fund was in compliance with the requirements of
subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 as of February 26,
2010, and from June 26, 2009 through February 26, 2010, with respect to securities reflected in the
investment accounts of the fund.
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By: |
/s/ Charles D. Gariboldi, Jr.
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Charles D. Gariboldi, Jr. |
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Treasurer
American Municipal Income Portfolio Inc. |
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Report of Independent Registered Public Accounting Firm
The Board of Directors
American Municipal Income Portfolio Inc.
We have examined managements assertion, included in the accompanying Management Statement
Regarding Compliance With Certain Provisions of the Investment Company Act of 1940, that the
American Municipal Income Portfolio Inc. (referred to as the fund) complied with the requirements
of subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 (the Act) as of
February 26, 2010. Management is responsible for the funds compliance with those requirements. Our
responsibility is to express an opinion on managements assertion about the funds compliance based
on our examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting
Oversight Board (United States) 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 as of February 26, 2010, and with respect to agreement of security purchases and sales,
for the period from June 26, 2009 (the date of our last examination) through February 26, 2010:
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Confirmation of all securities held by institutions in book entry form (Bank of New
York, Depository Trust Company, and Federal Reserve Bank of Boston); |
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Confirmation of all securities hypothecated, pledged, placed in escrow, or out for
transfer with brokers, pledgees, or transfer agents; |
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Reconciliation of all such securities to the books and records of the fund and U.S.
Bank National Association (the Custodian); |
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Review of one security purchase since our last report from the books and records of the
fund, noting it has been accurately reported and subsequently settled. |
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.
1
In our opinion, managements assertion that the fund complied with the requirements of subsections
(b) and (c) of rule 17f-2 of the Act as of February 26, 2010, with respect to securities reflected
in the investment accounts of the fund, is fairly stated, in all material respects.
This report is intended solely for the information and use of management and the Board of Directors
of the fund and the Securities and Exchange Commission and is not intended to be and should not be
used by anyone other than these specified parties.
//Ernst & Young LLP
Minneapolis, Minnesota
May 27, 2010
2
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
May 27, 2010
I, as a member of management of the American Strategic Income Portfolio Inc. (referred to as the
fund), am 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. I am also responsible for establishing and maintaining effective internal controls
over compliance with those requirements. I have performed an evaluation of the funds compliance
with the requirements of subsections (b) and (c) of rule 17f-2 as of February 26, 2010, and from
June 26, 2009 through February 26, 2010.
Based on this evaluation, I assert that the fund was in compliance with the requirements of
subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 as of February 26,
2010, and from June 26, 2009 through February 26, 2010, with respect to securities reflected in the
investment accounts of the fund.
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By: |
/s/ Charles D. Gariboldi, Jr.
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Charles D. Gariboldi, Jr. |
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Treasurer
American Strategic Income Portfolio Inc. |
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Report of Independent Registered Public Accounting Firm
The Board of Directors
American Strategic Income Portfolio Inc.
We have examined managements assertion, included in the accompanying Management Statement
Regarding Compliance With Certain Provisions of the Investment Company Act of 1940, that the
American Strategic Income Portfolio Inc. (referred to as the fund) complied with the requirements
of subsections (b) and (c) of rule 17f-2 under the Investment Company Act of 1940 (the Act) as of
February 26, 2010. Management is responsible for the funds compliance with those requirements. Our
responsibility is to express an opinion on managements assertion about the funds compliance based
on our examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting
Oversight Board (United States) 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 as of February 26, 2010, and with respect to agreement of security purchases and sales,
for the period from June 26, 2009 (the date of our last examination) through February 26, 2010:
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Count and inspection of underlying documentation of securities in whole loans
designated as being held in the vault of U.S. Bank National Association (the Custodian) in
St. Paul, Minnesota, without prior notice to management; |
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Confirmation of all securities held by institutions in book entry form (Bank of New
York, Depository Trust Company, and Federal Reserve Bank of Boston); |
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Reconciliation of confirmation results as to all such securities to the books and
records of the fund and the Custodian; |
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Confirmation of all reverse repurchase agreements with brokers/banks and agreement of
underlying collateral with the Custodians records; and |
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Review of one security purchase since our last report from the books and records of the
fund, noting it has been accurately reported and subsequently settled. |
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.
1
In our opinion, managements assertion that the fund complied with the requirements of subsections
(b) and (c) of rule 17f-2 of the Act as of February 26, 2010, with respect to securities reflected
in the investment accounts of the fund, is fairly stated, in all material respects.
This report is intended solely for the information and use of management and the Board of Directors
of the fund and the Securities and Exchange Commission and is not intended to be and should not be
used by anyone other than these specified parties.
//Ernst & Young LLP
Minneapolis, Minnesota
May 27, 2010
2
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
May 27, 2010
I, as a member of management of the American Strategic Income Portfolio Inc. II (referred to as the
fund), am 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. I am also responsible for establishing and maintaining effective internal controls
over compliance with those requirements. I have performed an evaluation of the funds compliance
with the requirements of subsections (b) and (c) of rule 17f-2 as of February 26, 2010, and from
June 26, 2009 through February 26, 2010.
Based on this evaluation, I assert that the fund was in compliance with the requirements of
subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 as of February 26,
2010, and from June 26, 2009 through February 26, 2010, with respect to securities reflected in the
investment accounts of the fund.
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By: |
/s/ Charles D. Gariboldi, Jr.
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Charles D. Gariboldi, Jr. |
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Treasurer
American Strategic Income Portfolio Inc. II |
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Report of Independent Registered Public Accounting Firm
The Board of Directors
American Strategic Income Portfolio Inc. II
We have examined managements assertion, included in the accompanying Management Statement
Regarding Compliance With Certain Provisions of the Investment Company Act of 1940, that the
American Strategic Income Portfolio Inc. II (referred to as the fund) complied with the
requirements of subsections (b) and (c) of rule 17f-2 under the Investment Company Act of 1940 (the
Act) as of February 26, 2010. Management is responsible for the funds compliance with those
requirements. Our responsibility is to express an opinion on managements assertion about the
funds compliance based on our examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting
Oversight Board (United States) 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 as of February 26, 2010, and with respect to agreement of security purchases and sales,
for the period from June 26, 2009 (the date of our last examination) through February 26, 2010:
|
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Count and inspection of underlying documentation of securities in whole loans
designated as being held in the vault of U.S. Bank National Association (the Custodian) in
St. Paul, Minnesota, without prior notice to management; |
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|
Confirmation of all securities held by institutions in book entry form (Bank of New
York, Depository Trust Company, and Federal Reserve Bank of Boston); |
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Reconciliation of confirmation results as to all such securities to the books and
records of the fund and the Custodian; |
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Confirmation of all reverse repurchase agreements with brokers/banks and agreement of
underlying collateral with the Custodians records; and |
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|
|
Review of one security sale or maturity since our last report from the books and
records of the fund, noting it has been accurately reported and subsequently settled. |
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.
1
In our opinion, managements assertion that the fund complied with the requirements of subsections
(b) and (c) of rule 17f-2 of the Act as of February 26, 2010, with respect to securities reflected
in the investment accounts of the fund, is fairly stated, in all material respects.
This report is intended solely for the information and use of management and the Board of Directors
of the fund and the Securities and Exchange Commission and is not intended to be and should not be
used by anyone other than these specified parties.
//Ernst & Young LLP
Minneapolis, Minnesota
May 27, 2010
2
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
May 27, 2010
I, as a member of management of the American Strategic Income Portfolio Inc. III (referred to as
the fund), am 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. I am also responsible for establishing and maintaining effective internal
controls over compliance with those requirements. I have performed an evaluation of the funds
compliance with the requirements of subsections (b) and (c) of rule 17f-2 as of February 26, 2010,
and from June 26, 2009 through February 26, 2010.
Based on this evaluation, I assert that the fund was in compliance with the requirements of
subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 as of February 26,
2010, and from June 26, 2009 through February 26, 2010, with respect to securities reflected in the
investment accounts of the fund.
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By: |
/s/ Charles D. Gariboldi, Jr.
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Charles D. Gariboldi, Jr. |
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Treasurer
American Strategic Income Portfolio Inc. III |
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Report of Independent Registered Public Accounting Firm
The Board of Directors
American Strategic Income Portfolio Inc. III
We have examined managements assertion, included in the accompanying Management Statement
Regarding Compliance With Certain Provisions of the Investment Company Act of 1940, that the
American Strategic Income Portfolio Inc. III (referred to as the fund) complied with the
requirements of subsections (b) and (c) of rule 17f-2 under the Investment Company Act of 1940 (the
Act) as of February 26, 2010. Management is responsible for the funds compliance with those
requirements. Our responsibility is to express an opinion on managements assertion about the
funds compliance based on our examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting
Oversight Board (United States) 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 as of February 26, 2010, and with respect to agreement of security purchases and sales,
for the period from June 26, 2009 (the date of our last examination) through February 26, 2010:
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|
Count and inspection of all securities located in the vault of U.S. Bank National
Association (the Custodian) in Milwaukee, Wisconsin, without prior notice to management; |
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|
|
Count and inspection of underlying documentation of securities in whole loans
designated as being held in the vault of the Custodian in St. Paul, Minnesota, without
prior notice to management; |
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|
|
Confirmation of all securities held by institutions in book entry form (Bank of New
York, Depository Trust Company, and Federal Reserve Bank of Boston); |
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|
Reconciliation of confirmation results as to all such securities to the books and
records of the fund and the Custodian; |
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Confirmation of all reverse repurchase agreements with brokers/banks and agreement of
underlying collateral with the Custodians records; and |
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|
Review of one security purchase since our last report from the books and records of the
fund, noting it has been accurately reported and subsequently settled. |
1
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, managements assertion that the fund complied with the requirements of subsections
(b) and (c) of rule 17f-2 of the Act as of February 26, 2010 with respect to securities reflected
in the investment accounts of the fund, is fairly stated, in all material respects.
This report is intended solely for the information and use of management and the Board of Directors
of the fund and the Securities and Exchange Commission and is not intended to be and should not be
used by anyone other than these specified parties.
//Ernst & Young LLP
Minneapolis, Minnesota
May 27, 2010
2
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
May 27, 2010
I, as a member of management of the following Funds:
Tax Free Funds - California Tax Free Fund, Colorado Tax Free Fund,
Intermediate Tax Free Fund, Minnesota Intermediate Tax Free Fund, Minnesota Tax Free Fund, Missouri
Tax Free Fund, Nebraska Tax Free Fund, Ohio Tax Free Fund, Oregon Intermediate Tax Free Fund, Tax
Free Fund, and Short Tax Free Fund;
Bond Funds Core Bond Fund, High Income Bond Fund, Total Return Bond Fund, Intermediate Term Bond
Fund, Short Term Bond Fund, Intermediate Government Bond Fund, and Inflation Protected Securities
Fund;
Equity Funds Real Estate Securities Fund, Mid Cap Select, Small Cap Growth Opportunities Fund,
Small Cap Value Fund, Small Cap Select Fund, Mid Cap Value Fund, Mid Cap Growth Opportunities Fund,
Large Cap Value Fund, Large Cap Select Fund, Large Cap Growth Opportunities Fund, Tactical Market
Opportunities Fund and Equity Income Fund;
Quantitative Funds - Quantitative Large Cap Core Fund, Quantitative Large Cap Growth Fund, and
Quantitative Large Cap Value Fund;
Index Funds Equity Index Fund, Mid Cap Index Fund, and Small Cap Index Fund;
of the First American Investment Funds, Inc. (referred to collectively as the funds), am
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. I am also responsible for establishing and maintaining effective internal controls over
compliance with those requirements. I have performed an evaluation of the funds compliance with
the requirements of subsections (b) and (c) of rule 17f-2 as of February 26, 2010, and from June
26, 2009 through February 26, 2010.
Based on this evaluation, I assert that 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 February 26,
2010, and from June 26, 2009 to February 26, 2010, with respect to securities reflected in the
investment accounts of the funds.
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By: |
/s/ Charles D. Gariboldi, Jr.
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Charles D. Gariboldi, Jr. |
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Treasurer
First American Investment Funds, Inc. |
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Report of Independent Registered Public Accounting Firm
The Board of Directors
First American Investment Funds, Inc.
We have examined managements assertion, included in the accompanying Management Statement
Regarding Compliance With Certain Provisions of the Investment Company Act of 1940, that the
following Funds:
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Tax Free Funds California Tax Free Fund, Colorado Tax Free Fund, Intermediate Tax Free Fund,
Minnesota Intermediate Tax Free Fund, Minnesota Tax Free Fund, Missouri Tax Free Fund, Nebraska
Tax Free Fund, Ohio Tax Free Fund, Oregon Intermediate Tax Free Fund, Tax Free Fund, and Short
Tax Free Fund; |
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Bond Funds Core Bond Fund, High Income Bond Fund, Total Return Bond Fund, Intermediate Term
Bond Fund, Short Term Bond Fund, Intermediate Government Bond Fund, and Inflation Protected
Securities Fund; |
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Equity Funds Real Estate Securities Fund, Mid Cap Select Fund, Small Cap Growth Opportunities
Fund, Small Cap Value Fund, Small Cap Select Fund, Mid Cap Value Fund, Mid Cap Growth
Opportunities Fund, Large Cap Value Fund, Large Cap Select Fund, Large Cap Growth Opportunities
Fund, and Equity Income Fund, Tactical Market Opportunities Fund; |
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Quantitative Funds Quantitative Large Cap Core Fund, Quantitative Large Cap Growth Fund, and
Quantitative Large Cap Value Fund; |
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Index Funds Equity Index Fund, Mid Cap Index Fund, and Small Cap Index Fund; |
of the First American Investment Funds, Inc. (referred to collectively as the funds) complied with
the requirements of subsections (b) and (c) of rule 17f-2 under the Investment Company Act of 1940
(the Act) as of February 26, 2010. Management is responsible for the funds compliance with those
requirements. Our responsibility is to express an opinion on managements assertion about the
funds compliance based on our examination.
1
Our examination was conducted in accordance with the standards of the Public Company Accounting
Oversight Board (United States) 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 as of February 26, 2010, and with respect to agreement of security purchases and sales,
for the period from June 26, 2009 (the date of our last examination) through February 26, 2010:
|
|
|
Count and inspection of all securities located in the vault of U.S. Bank National
Association (the Custodian) in Milwaukee, Wisconsin, without prior notice to management; |
|
|
|
|
Confirmation of all securities held by institutions in book entry form (Bank of New
York, Depository Trust Company, and Federal Reserve Bank of Boston); |
|
|
|
|
Confirmation of all securities hypothecated, pledged, placed in escrow, or out for
transfer with brokers, pledgees, or transfer agents; |
|
|
|
|
Reconciliation of all such securities to the books and records of the funds and the
Custodian; and |
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|
|
|
Review of five security purchases and six security sales or maturities since our last
report from the books and records of the funds, noting they have been accurately reported
and subsequently settled. |
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, managements assertion that the funds complied with the requirements of subsections
(b) and (c) of rule 17f-2 of the Act as of February 26, 2010, with respect to securities reflected
in the investment accounts of the funds, is fairly stated, in all material respects.
This report is intended solely for the information and use of management and the Board of Directors
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.
//Ernst & Young LLP
Minneapolis, Minnesota
May 27, 2010
2
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
May 27, 2010
I, as a member of management of the First American Minnesota Municipal Income Fund II, Inc.
(referred to as the fund), am 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. I am also responsible for establishing and maintaining
effective internal controls over compliance with those requirements. I have performed an evaluation
of the funds compliance with the requirements of subsections (b) and (c) of rule 17f-2 as of
February 26, 2010, and from June 26, 2009 through February 26, 2010.
Based on this evaluation, I assert that the fund was in compliance with the requirements of
subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 as of February 26,
2010, and from June 26, 2009 through February 26, 2010, with respect to securities reflected in the
investment accounts of the fund.
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By: |
/s/ Charles D. Gariboldi, Jr.
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Charles D. Gariboldi, Jr. |
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Treasurer
First American Minnesota Municipal Income Fund II Inc. |
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Report of Independent Registered Public Accounting Firm
The Board of Directors
First American Minnesota Municipal Income Fund II, Inc.
We have examined managements assertion, included in the accompanying Management Statement
Regarding Compliance With Certain Provisions of the Investment Company Act of 1940, that the First
American Minnesota Municipal Income Fund II, Inc. (referred to as the fund) complied with the
requirements of subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 (the
Act) as of February 26, 2010. Management is responsible for the funds compliance with those
requirements. Our responsibility is to express an opinion on managements assertion about the
funds compliance based on our examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting
Oversight Board (United States) 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 as of February 26, 2010, and with respect to agreement of security purchases and sales,
for the period from June 26, 2009 (the date of our last examination) through February 26, 2010:
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Confirmation of all securities held by institutions in book entry form (Bank of New
York, Depository Trust Company, and Federal Reserve Bank of Boston); |
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Confirmation of all securities hypothecated, pledged, placed in escrow, or out for
transfer with brokers, pledgees, or transfer agents; |
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Reconciliation of all such securities to the books and records of the fund and U.S.
Bank National Association (the Custodian); |
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Review of one security sale or maturity since our last report from the books and
records of the fund, noting it has been accurately reported and subsequently settled. |
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.
1
In our opinion, managements assertion that the fund complied with the requirements of subsections
(b) and (c) of rule 17f-2 of the Act as of February 26, 2010, with respect to securities reflected
in the investment accounts of the fund, is fairly stated, in all material respects.
This report is intended solely for the information and use of management and the Board of Directors
of the fund and the Securities and Exchange Commission and is not intended to be and should not be
used by anyone other than these specified parties.
//Ernst & Young LLP
Minneapolis, Minnesota
May 27, 2010
2
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
May 27, 2010
I, as a member of management of the Minnesota Municipal Income Portfolio Inc. (referred to as the
fund), am 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. I am also responsible for establishing and maintaining effective internal controls
over compliance with those requirements. I have performed an evaluation of the funds compliance
with the requirements of subsections (b) and (c) of rule 17f-2 as of February 26, 2010, and from
June 26, 2009 through February 26, 2010.
Based on this evaluation, I assert that the fund was in compliance with the requirements of
subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 as of February 26,
2010, and from June 26, 2009 through February 26, 2010, with respect to securities reflected in the
investment accounts of the fund.
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By: |
/s/ Charles D. Gariboldi, Jr.
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Charles D. Gariboldi, Jr. |
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Treasurer
Minnesota Municipal Income Portfolio Inc. |
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Report of Independent Registered Public Accounting Firm
The Board of Directors
Minnesota Municipal Income Portfolio Inc.
We have examined managements assertion, included in the accompanying Management Statement
Regarding Compliance With Certain Provisions of the Investment Company Act of 1940, that the
Minnesota Municipal Income Portfolio Inc. (referred to as the fund) complied with the requirements
of subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 (the Act) as of
February 26, 2010. Management is responsible for the funds compliance with those requirements. Our
responsibility is to express an opinion on managements assertion about the funds compliance based
on our examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting
Oversight Board (United States) 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 as of February 26, 2010, and with respect to agreement of security purchases and sales,
for the period from June 26, 2009 (the date of our last examination) through February 26, 2010:
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Count and inspection of all securities located in the vault of U.S. Bank National
Association (the Custodian) in Milwaukee, Wisconsin, without prior notice to management; |
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Confirmation of all securities held by institutions in book entry form (Bank of New
York, Depository Trust Company, and Federal Reserve Bank of Boston); |
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Confirmation of all securities hypothecated, pledged, placed in escrow, or out for
transfer with brokers, pledgees, or transfer agents; |
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Reconciliation of all such securities to the books and records of the fund and the
Custodian; |
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Review of one purchase since our last report from the books and records of the fund,
noting it has been accurately reported and subsequently settled. |
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.
1
In our opinion, managements assertion that the fund complied with the requirements of subsections
(b) and (c) of rule 17f-2 of the Act as of February 26, 2010, with respect to securities reflected
in the investment accounts of the fund, is fairly stated, in all material respects.
This report is intended solely for the information and use of management and the Board of Directors
of the fund and the Securities and Exchange Commission and is not intended to be and should not be
used by anyone other than these specified parties.
//Ernst & Young LLP
Minneapolis, Minnesota
May 27, 2010
2
Management Statement Regarding Compliance With Certain Provisions of the
Investment Company Act of 1940
May 27, 2010
I, as a member of management of the Mount Vernon Securities Lending Prime Portfolio of the Mount
Vernon Securities Lending Trust (referred to as the portfolio), am 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. I am also responsible for
establishing and maintaining effective internal controls over compliance with those requirements. I
have performed an evaluation of the portfolios compliance with the requirements of subsections (b)
and (c) of rule 17f-2 as of February 26, 2010, and from June 26, 2009 through February 26, 2010.
Based on this evaluation, I assert that the portfolio was in compliance with the requirements of
subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 as of February 26,
2010, and from June 26, 2009 through February 26, 2010, with respect to securities reflected in the
investment accounts of the portfolio.
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By: |
/s/ Charles D. Gariboldi, Jr.
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Charles D. Gariboldi, Jr. |
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Treasurer
Mount Vernon Securities Lending Trust |
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Report of Independent Registered Public Accounting Firm
The Board of Directors
Mount Vernon Securities Lending Trust
We have examined managements assertion, included in the accompanying Management Statement
Regarding Compliance With Certain Provisions of the Investment Company Act of 1940, that the Mount
Vernon Securities Lending Prime Portfolio of the Mount Vernon Securities Lending Trust (referred to
as the portfolio) complied with the requirements of subsections (b) and (c) of rule 17f-2 under the
Investment Company Act of 1940 (the Act) as of February 26, 2010. Management is responsible for the
portfolios compliance with those requirements. Our responsibility is to express an opinion on
managements assertion about the portfolios compliance based on our examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting
Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence
about the portfolios 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 February 26, 2010, and with respect to agreement of security purchases and sales,
for the period from June 26, 2009 (the date of our last examination) through February 26, 2010:
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Confirmation of all securities held by institutions in book entry form (Bank of New
York, Depository Trust Company, and Federal Reserve Bank of Boston); |
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Confirmation of all securities hypothecated, pledged, placed in escrow, or out for
transfer with brokers, pledgees, or transfer agents; |
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Reconciliation of all such securities to the books and records of the portfolio and
U.S. Bank National Association (the Custodian). |
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Confirmation of all repurchase agreements with brokers/banks and agreement of
underlying collateral with the Custodians records; and |
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Review of two security purchases and one security sale or maturity since our last
report from the books and records of the portfolio, noting they have been accurately
reported and subsequently settled. |
We believe that our examination provides a reasonable basis for our opinion. Our examination does
not provide a legal determination on the portfolios compliance with specified requirements.
In our opinion, managements assertion that the portfolio complied with the requirements of
subsections (b) and (c) of rule 17f-2 of the Act as of February 26, 2010, with respect to
securities reflected in the investment accounts of the portfolio, is fairly stated, in all material
respects.
This report is intended solely for the information and use of management and the Board of Directors
of the portfolio and the Securities and Exchange Commission and is not intended to be and should
not be used by anyone other than these specified parties.
//Ernst & Young LLP
Minneapolis, Minnesota
May 27, 2010
2
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
May 27, 2010
I, as a member of management of the American Select Portfolio Inc. (referred to as the fund), am
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. I am also responsible for establishing and maintaining effective internal controls over
compliance with those requirements. I have performed an evaluation of the funds compliance with
the requirements of subsections (b) and (c) of rule 17f-2 as of February 26, 2010, and from June
26, 2009 through February 26, 2010.
Based on this evaluation, I assert that the fund was in compliance with the requirements of
subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 as of February 26,
2010, and from June 26, 2009 through February 26, 2010, with respect to securities reflected in the
investment accounts of the fund.
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By: |
/s/ Charles D. Gariboldi, Jr.
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Charles D. Gariboldi, Jr. |
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Treasurer
American Select Portfolio Inc. |
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Report of Independent Registered Public Accounting Firm
The Board of Directors
American Select Portfolio Inc.
We have examined managements assertion, included in the accompanying Management Statement
Regarding Compliance With Certain Provisions of the Investment Company Act of 1940, that the
American Select Portfolio Inc. (referred to as the fund) complied with the requirements of
subsections (b) and (c) of rule 17f-2 under the Investment Company Act of 1940 (the Act) as of
February 26, 2010. Management is responsible for the funds compliance with those requirements. Our
responsibility is to express an opinion on managements assertion about the funds compliance based
on our examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting
Oversight Board (United States) 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 as of February 26, 2010, and with respect to agreement of security purchases and sales,
for the period from June 26, 2009 (the date of our last examination) through February 26, 2010:
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Count and inspection of underlying documentation of securities in whole loans
designated as being held in the vault of U.S. Bank National Association (the Custodian) in
St. Paul, Minnesota, without prior notice to management; |
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Confirmation of all securities held by institutions in book entry form (Bank of New
York, Depository Trust Company, and Federal Reserve Bank of Boston); |
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Reconciliation of confirmation results as to all such securities to the books and
records of the fund and the Custodian; |
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Confirmation of all reverse repurchase agreements with brokers/banks and agreement of
underlying collateral with the Custodians records; and |
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Review of one security sale or maturity since our last report from the books and
records of the fund, noting it has been accurately reported and subsequently settled. |
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.
1
In our opinion, managements assertion that the fund complied with the requirements of subsections
(b) and (c) of rule 17f-2 of the Act as of February 26, 2010, with respect to securities reflected
in the investment accounts of the fund, is fairly stated, in all material respects.
This report is intended solely for the information and use of management and the Board of Directors
of the fund and the Securities and Exchange Commission and is not intended to be and should not be
used by anyone other than these specified parties.
//Ernst & Young LLP
Minneapolis, Minnesota
May 27, 2010
2
Management Statement Regarding Compliance With Certain Provisions of the
Investment Company Act of 1940
May 27, 2010
I, as a member of management of the Strategy Aggressive Growth Allocation Fund, Strategy Balanced
Allocation Fund, Strategy Growth Allocation Fund, and Strategy Conservative Allocation Fund of the
First American Strategy Funds, Inc. (referred to collectively as the funds), am 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. I am also
responsible for establishing and maintaining effective internal controls over compliance with those
requirements. I have performed an evaluation of the funds compliance with the requirements of
subsections (b) and (c) of rule 17f-2 as of February 26, 2010, and from June 26, 2009 through
February 26, 2010.
Based on this evaluation, I assert that 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 February 26,
2010, and from June 26, 2009 through February 26, 2010, with respect to securities reflected in the
investment accounts of the funds.
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By: |
/s/ Charles D. Gariboldi, Jr.
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Charles D. Gariboldi, Jr. |
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Treasurer
First American Strategy Funds, Inc. |
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Report of Independent Registered Public Accounting Firm
The Board of Directors
First American Strategy Funds, Inc.
We have examined managements assertion, included in the accompanying Management Statement
Regarding Compliance With Certain Provisions of the Investment Company Act of 1940, that the
Strategy Aggressive Growth Allocation Fund, Strategy Balanced Allocation Fund, Strategy Growth
Allocation Fund, and Strategy Conservative Allocation Fund of the First American Strategy Funds,
Inc. (referred to collectively as the funds) complied with the requirements of subsections (b) and
(c) of rule 17f-2 of the Investment Company Act of 1940 (the Act) as of February 26, 2010.
Management is responsible for the funds compliance with those requirements. Our responsibility is
to express an opinion on managements assertion about the funds compliance based on our
examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting
Oversight Board (United States) 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 as of February 26, 2010, and with respect to agreement of security purchases and sales,
for the period from June 26, 2009 (the date of our last examination) through February 26, 2010:
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Confirmation of all securities held by institutions in book entry form (Bank of New
York, Depository Trust Company, and Federal Reserve Bank of Boston); |
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Reconciliation of all such securities to the books and records of the funds and U.S.
Bank National Association (the Custodian); |
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Review of one security purchase and one security sale or maturity since our last report
from the books and records of the funds, noting they have been accurately reported and
subsequently settled. |
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.
1
In our opinion, managements assertion that the funds complied with the requirements of subsections
(b) and (c) of rule 17f-2 of the Act as of February 26, 2010, with respect to securities reflected
in the investment accounts of the funds, is fairly stated, in all material respects.
This report is intended solely for the information and use of management and the Board of Directors
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.
//Ernst & Young LLP
Minneapolis, Minnesota
May 27, 2010
2
Management Statement Regarding Compliance With Certain Provisions of the
Investment Company Act of 1940
May 27, 2010
I, as a member of management of the Government Obligations Fund, Prime Obligations Fund, Tax Free
Obligations Fund, Treasury Obligations Fund, and U.S. Treasury Money Market Fund of the First
American Funds, Inc. (referred to collectively as the funds), am 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. I am also responsible for
establishing and maintaining effective internal controls over compliance with those requirements. I
have performed an evaluation of the funds compliance with the requirements of subsections (b) and
(c) of rule 17f-2 as of February 26, 2010, and from June 26, 2009 through February 26, 2010.
Based on this evaluation, I assert that 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 February 26,
2010, and from June 26, 2009 through February 26, 2010, with respect to securities reflected in the
investment accounts of the funds.
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By:
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/s/ Charles D. Gariboldi, Jr. |
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Charles D. Gariboldi, Jr.
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Treasurer |
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First American Funds, Inc. |
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Report of Independent Registered Public Accounting Firm
The Board of Directors
First American Funds, Inc.
We have examined managements assertion, included in the accompanying Management Statement
Regarding Compliance With Certain Provisions of the Investment Company Act of 1940, that the
Government Obligations Fund, Prime Obligations Fund, Tax Free Obligations Fund, Treasury
Obligations Fund, and U.S. Treasury Money Market Fund of the First American Funds, Inc. (referred
to collectively as the funds) complied with the requirements of subsections (b) and (c) of rule
17f-2 under the Investment Company Act of 1940 (the Act) as of February 26, 2010. Management is
responsible for the funds compliance with those requirements. Our responsibility is to express an
opinion on managements assertion about the funds compliance based on our examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting
Oversight Board (United States) 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 as of February 26, 2010, and with respect to agreement of security purchases and sales,
for the period from June 26, 2009 (the date of our last examination) through February 26, 2010:
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Confirmation of all securities held by institutions in book entry form (Bank of New
York, Depository Trust Company, and Federal Reserve Bank of Boston); |
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Confirmation of all securities hypothecated, pledged, placed in escrow, or out for
transfer with brokers, pledgees, or transfer agents; |
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Reconciliation of all such securities to the books and records of the funds and the
Custodian; |
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Confirmation of all repurchase agreements with brokers/banks and agreement of
underlying collateral with the Custodians records; and |
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Review of one security purchase since our last report from the books and records of the
funds, noting they have been accurately reported and subsequently settled. |
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.
1
In our opinion, managements assertion that the funds complied with the requirements of subsections
(b) and (c) of rule 17f-2 of the Act as of February 26, 2010, with respect to securities reflected
in the investment accounts of the funds, is fairly stated, in all material respects.
This report is intended solely for the information and use of management and the Board of Directors
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.
//Ernst & Young LLP
Minneapolis, Minnesota
May 27, 2010
2