U.S. 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]
1. Investment Company Act File Number: Date examination completed:
811-6082 October 31, 2002
2. State Identification Number:
AL AK AZ AR CA CO
CT DE DC FL GA HI
ID IL IN IA KS KY
LA ME MD MA MI MN
MS MO MT NE NV NH
NJ NM NY NC ND OH
OK OR PA RI SC SD
TN TX UT VT VA WA
WV WI WY PUERTO RICO
Other (specify):
3. Exact number of investment company as specified in registration statement:
THE RIVERFRONT FUNDS
4. Address of principal executive office:
(number, street, city, state, zip code)
1001 LIBERTY AVENUE
PITTSBURGH, PA 15222-3779
INSTRUCTIONS
This Form must be completed by the investment companies that have custody
of securities or similar investments.
Investment Company
1. All items must be completed by the investment company.
2. Give this Form to the independent public accountant who, in compliance with
Rule 17f-2 under the Act and applicable state law, examines securities and
similar investments in the custody of the investment company.
Accountant
3. Submit this Form to the Securities and Exchange Commission and appropriate
state securities administrators when filing the certificate of accounting
required by Rule 17f-2 under the Act and applicable state law. File the
original and one copy with the Securities and Exchange Commission's
principal office in Washington, D.C., one copy with the regional office for
the region in which the investment company's principal business operations
are conducted, and one copy with the appropriate state administrator(s), if
applicable.
THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT
Note: The estimated average burden hours are made solely for purposes of
the Paperwork Reduction Act, and are not derived from a comprehensive or even a
representative survey or study of the costs of SEC rules and forms. Direct any
comments concerning the accuracy of the estimated average burden hours for
compliance with SEC rules and forms to Kenneth A. Fogash, Deputy Executive
Director, U.S. Securities and Exchange Commission, 450 Fifth Street, N.W.,
Washington, D.C. 20549 and Gary Waxman, Clearance Officer, Office of Management
and Budget, Room 3208 New Executive Office Building, Washington, D.C. 20503.
Report of Management on Compliance With Rule 17f-2 of the
Investment Company Act of 1940
December 13, 2002
We, as members of management of The Riverfront Funds (the "Funds"), are
responsible for complying with the requirements of subsections (b) and (c) of
Rule 17f-2, "Custody of Investments by Registered Management Investment
Companies," of the Investment Company Act of 1940. We also are responsible
for establishing and maintaining effective internal control over compliance
with those requirements. We have performed an evaluation of the Funds'
compliance with the requirements of subsections (b) and (c) of Rule 17f-2 as
of October 31, 2002, and from September 30, 2002 (the date of the last
examination) through October 31, 2002.
Based on this evaluation, we 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 October 31, 2002, and from September 30, 2002 (the
date of the last examination) through October 31, 2002, with respect to
securities and similar investments reflected in the investment accounts of
the Funds.
/s/ Duane Dewey
Duane Dewey
President
/s/ Timothy S. Johnson
Timothy S. Johnson
Secretary
/s/ C. John Ollier
C. John Ollier
Treasurer
Report of Independent Accountants
To the Board of Trustees of
The Riverfront Funds
We have examined management's assertion, included in the accompanying
"Report of Management on Compliance with Rule 17f-2 of the Investment Company
Act of 1940," that The Riverfront Funds, comprised of U.S. Government Securities
Money Market Fund, Small Company Select Fund, Balanced Fund, U.S. Government
Income Fund, Select Value Fund, and Large Company Select Fund (collectively, 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 October 31, 2002
with respect to securities and similar investments reflected in the investment
account of the Funds. Management is responsible for the Funds' compliance with
those requirements. Our responsibility is to express an opinion on management's
assertion based on our examination.
Our examination was conducted without prior notice to management. Our
examination was conducted in accordance with attestation standards established
by the American Institute of Certified Public Accountants and, accordingly,
included examining, on a test basis, evidence about the Funds' compliance with
those requirements and performing such other procedures as we considered
necessary in the circumstances. Included among our procedures were the following
tests performed as of October 31, 2002, and with respect to agreement of
security and similar investments purchases and sales, for the period from
September 30, 2002 (the date of our last examination) through October 31, 2002:
o Confirmation of all securities and similar investments held by the Federal
Reserve Bank of Cleveland, Deutsche Bank and The Depository Trust Company
in book entry form;
o Reconciliation of confirmation results as to all such securities and
investments to the books and records of the Funds and the Custodian,
Provident Bank;
o Confirmation of repurchase agreement with the broker and agreement of the
underlying collateral with Provident Bank's records; and
o Agreement of six security and/or investment purchases and six security
and/or investment 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, management's assertion that The Riverfront Funds complied
with the requirements of subsections (b) and (c) of Rule 17f-2 of the Investment
Company Act of 1940 as of October 31, 2002, with respect to securities and
similar investments 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 the board of
trustees and management of The Riverfront 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
Cincinnati, Ohio
December 13, 2002