e40v17f2
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OMB APPROVAL |
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OMB Number:
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3235-0360 |
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Expires:
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July 31,
2009 |
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Estimated average burden hours per
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1.0 |
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:
June 30, 2007 |
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2.
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State identification Number: |
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NH |
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NJ |
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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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UT |
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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
December 19, 2007
I, as a member of management of the Strategy Aggressive Allocation Fund, Strategy Growth & Income
Allocation Fund, Strategy Growth Allocation Fund, Strategy Income Allocation Fund, and Income
Builder 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 June 30, 2007, and from May
17, 2007 through June 30, 2007.
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 June 30, 2007,
and from May 17, 2007 through June 30, 2007, with respect to securities reflected in the investment
accounts of the funds.
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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 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 (the Act), that
the Strategy Aggressive Allocation Fund, Strategy Growth & Income Allocation Fund, Strategy Growth
Allocation Fund, Strategy Income Allocation Fund, and the Income Builder Fund of 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 Act as of June 30, 2007. 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 June 30, 2007, and with respect to agreement of security purchases and sales, for
the period from May 17, 2007 (the date of our last examination) through June 30, 2007:
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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
U.S. Bank National Association (the Custodian); and |
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Agreement of two security purchases and two security sales or maturities since our last
examination from the books and records of the funds to broker confirmations or cash
settlement with custody. |
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 June 30, 2007, 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.
Minneapolis, Minnesota
December 19, 2007
Management Statement Regarding Compliance With Certain Provisions of the
Investment Company Act of 1940
December 19, 2007
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 June 30, 2007, and from May 17, 2007 through June 30, 2007.
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 June 30, 2007,
and from May 17, 2007 through June 30, 2007, with respect to securities reflected in the investment
accounts of the funds.
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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 (the Act), that
the Government Obligations Fund, Prime Obligations Fund, Tax Free Obligations Fund, Treasury
Obligations Fund, and U.S. Treasury Money Market Fund of 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 Act as of June 30, 2007. 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 June 30, 2007, and with respect to agreement of security purchases and sales, for
the period from May 17, 2007 (the date of our last examination) through June 30, 2007:
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Confirmation of all securities held by institutions in book entry form (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 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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Agreement of two security purchases and one security sale or maturity since our last
examination 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, managements assertion that the funds complied with the requirements of subsections
(b) and (c) of Rule 17f-2 of the Act as of June 30, 2007, 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.
Minneapolis, Minnesota
December 19, 2007
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
December 19, 2007
I, as a member of management of the following funds:
Tax
Free Funds Arizona Tax Free Fund, California Intermediate Tax Free Fund, California Tax Free
Fund, Colorado Intermediate 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, 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, U.S. Government Mortgage Fund, Intermediate Government Bond Fund,
Inflation Protected Securities Fund;
Equity Funds Real Estate Securities Fund, Small Mid Cap Core 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, Balanced Fund, Equity Income 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 June 30, 2007, and from May 17,
2007 through June 30, 2007.
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 June 30, 2007,
and from May 17, 2007 to June 30, 2007, with respect to securities reflected in the investment
accounts of the funds.
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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 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 (the Act), that
the following funds:
Tax Free Funds Arizona Tax Free Fund, California Intermediate Tax Free Fund, California
Tax Free Fund, Colorado Intermediate 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, 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, U.S. Government Mortgage Fund, Intermediate Government
Bond Fund, Inflation Protected Securities Fund;
Equity Funds Real Estate Securities Fund, Small Mid Cap Core 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, Balanced Fund, Equity Income Fund;
Index Funds Equity Index Fund, Mid Cap Index Fund, and Small Cap Index Fund;
of 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 Act as of June 30, 2007. 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 June 30, 2007, and with respect to agreement of security purchases and sales, for
the period from May 17, 2007 (the date of our last examination) through June 30, 2007:
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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; |
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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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Agreement of eight security purchases and ten security sales or maturities since our
last examination 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, managements assertion that the funds complied with the requirements of subsections
(b) and (c) of Rule 17f-2 of the Act as of June 30, 2007, 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.
Minneapolis, Minnesota
December 19, 2007
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
December 19, 2007
I, as a member of management of the American Income Fund, Inc., American Municipal Income Portfolio
Inc., First American Minnesota Municipal Income Fund II, Inc., and Minnesota Municipal Income
Portfolio 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 June 30, 2007, and from May 17, 2007 through June 30, 2007.
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 June 30, 2007,
and from May 17, 2007 through June 30, 2007, with respect to securities reflected in the investment
accounts of the funds.
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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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American Income Fund, Inc. |
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American Municipal Income Portfolio Inc. |
First American Minnesota Municipal Income Fund II, Inc. |
Minnesota Municipal Income Portfolio Inc. |
Report of Independent Registered Public Accounting Firm
The Board of Directors
American Income Fund, Inc.
American Municipal Income Portfolio Inc.
First American Minnesota Municipal Income Fund II, Inc.
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 (the Act), that
the American Income Fund, Inc., American Municipal Income Portfolio Inc., First American Minnesota
Municipal Income Fund II, Inc., and Minnesota Municipal Income Portfolio Inc. (referred to
collectively as the funds) complied with the requirements of subsections (b) and (c) of Rule 17f-2
of the Act as of June 30, 2007. 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 June 30, 2007, and with respect to agreement of security purchases and sales, for
the period from May 17, 2007 (the date of our last examination) through June 30, 2007:
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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, and St. Paul, Minnesota; |
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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; and |
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Agreement of five security purchases and five security sales or maturities since our
last examination 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, managements assertion that the funds complied with the requirements of subsections
(b) and (c) of Rule 17f-2 of the Act as of June 30, 2007, 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.
Minneapolis, Minnesota
December 19, 2007
Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940
December 19, 2007
I, as a member of management of the American Strategic Income Portfolio Inc., American Strategic
Income Portfolio Inc. II, American Strategic Income Portfolio Inc. III, and American Select
Portfolio 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 June 30, 2007, and from May 17, 2007 through June 30, 2007.
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 June 30, 2007,
and from May 17, 2007 through June 30, 2007, with respect to securities reflected in the investment
accounts of the funds.
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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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American Strategic Income Portfolio Inc. |
American Strategic Income Portfolio Inc. II |
American Strategic Income Portfolio Inc. III |
American Select Portfolio Inc. |
Report of Independent Registered Public Accounting Firm
The Board of Directors
American Strategic Income Portfolio Inc.
American Strategic Income Portfolio Inc. II
American Strategic Income Portfolio Inc. III
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 (the Act), that
American Strategic Income Portfolio Inc., American Strategic Income Portfolio Inc. II, American
Strategic Income Portfolio Inc. III, and American Select Portfolio Inc. (referred to collectively
as the portfolios) complied with the requirements of subsections (b) and (c) of Rule 17f-2 of the
Act as of June 30, 2007. 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 June 30, 2007, and with respect to agreement of security purchases and sales, for
the period from May 17, 2007 (the date of our last examination) through June 30, 2007:
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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; |
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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; |
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Confirmation of all securities held by institutions in book entry form (Depository Trust
Company and Federal Reserve Bank of Boston); |
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Reconciliation of confirmation results as to all such securities in whole loans to the
books and records of the portfolios 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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Agreement of three security purchases and three security sales or maturities since our
last examination from the books and records of the portfolios 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 portfolios compliance with specified requirements.
In our opinion, managements assertion that the portfolios complied with the requirements of
subsections (b) and (c) of Rule 17f-2 of the Act as of June 30, 2007, with respect to securities
reflected in the investment accounts of the portfolios, 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 portfolios and the Securities and Exchange Commission and is not intended to be and should
not be used by anyone other than these specified parties.
Minneapolis, Minnesota
December 19, 2007
Management Statement Regarding Compliance With Certain Provisions of the
Investment Company Act of 1940
December 19, 2007
I, as a member of management of the Mount Vernon Securities Lending Prime Portfolio and Mount
Vernon Securities Lending Short-Term Bond Portfolio of the Mount Vernon Securities Lending Trust
(referred to collectively as the portfolios), 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 June 30, 2007, and from May 17, 2007 through June 30, 2007.
Based on this evaluation, I assert that the portfolios were in compliance with the requirements of
subsections (b) and (c) of rule 17f-2 as of June 30, 2007, and from May 17, 2007 through June 30,
2007, with respect to securities reflected in the investment accounts of the portfolios.
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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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Mount Vernon Securities Lending Trust |
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 (the Act), that
the Mount Vernon Securities Lending Prime Portfolio and Mount Vernon Securities Lending Short-Term
Bond Portfolio of the Mount Vernon Securities Lending Trust (referred to collectively as the
portfolios) complied with the requirements of subsections (b) and (c) of Rule 17f-2 under the Act
as of June 30, 2007. 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 June 30, 2007, and with respect to agreement of security purchases and sales, for
the period from May 17, 2007 (the date of our last examination) through June 30, 2007:
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Confirmation of all securities held by institutions in book entry form (Depository Trust
Company); |
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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 portfolios 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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Agreement of six security purchases and six security sales or maturities since our last
examination from the books and records of the portfolios 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 portfolios compliance with specified requirements.
In our opinion, managements assertion that the portfolios complied with the requirements of
subsections (b) and (c) of Rule 17f-2 of the Act as of June 30, 2007, with respect to securities
reflected in the investment accounts of the portfolios, 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 portfolios and the Securities and Exchange Commission and is not intended to be and should
not be used by anyone other than these specified parties.
Minneapolis, Minnesota
December 19, 2007