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:
33-40428 April 30, 2003
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 companies as specified in registration statement:
Riggs U.S. Government Fund
Riggs Small Company Stock Fund
Riggs Stock Fund
Riggs Prime Money Market Fund
Riggs U.S. Treasury Money Market Fund
Riggs Short Term Tax-Free Bond Fund
(formerly Riggs Intermediate Tax-Free Bond Fund)
Riggs Intermediate Tax-Free Bond Fund
(formerly Riggs Long-Term Tax-Free Bond Fund)
Riggs Bond Fund
4. Address of principal executive office:
(number, street, city, state, zip code)
Federated Investors Tower
1001 Liberty Avenue
Pittsburgh, PA 152222-3779
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.
June 11, 2003
KPMG LLP
99 High Street
Boston, MA 02110
RE: Management Statement Regarding Compliance with Certain Provisions of the
Investment Company Act of 1940
Ladies and Gentlemen:
We, as members of management of the funds listed in Appendix A, Riggs 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 are also
responsible for establishing and maintaining effective internal controls 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 April 30, 2003, and from January 31, 2003 through April 30, 2003.
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 April 30, 2003, and from January 31, 2003 through April 30,
2003, with respect to securities reflected in the investment accounts.
Sincerely,
Riggs Bank, N.A.
/s/ Virginia Lewis
Vice President and
Trust Operations Officer
Independent Auditors' Report
To the Board of Trustees
Riggs Funds
We have examined management's assertion, included in the accompanying Management
Statement Regarding Compliance with Certain Provisions of the Investment Company
Act of 1940, that Riggs Funds (the "Funds") as listed in Appendix A, complied
with the requirements of subsections (b) and (c) of Rule 17f-2 under the
Investment Company Act of 1940 (the Act) as of April 30, 2003. Management is
responsible for the Funds' compliance with those requirements. Our
responsibility is to express an opinion on management's assertion about the
Funds' compliance based on our examination.
Our examination was 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 April 30, 2003, and with respect to
agreement of security purchases and sales, for the period from January 31, 2003,
the date of the last examination, through April 30, 2003:
(1) Count and inspection of documentation of all securities located in the
vault, if any, of Riggs Bank, the Custodian;
(2) Inspection of documentation of securities held in book entry form by the
Bank of New York and examination of selected security position
reconciliations;
(3) Inspection of documentation of all securities purchased but not received,
hypothecated, pledged, placed in escrow, or out for transfer with brokers,
pledges and/or transfer agents;
(4) Reconciliation of all such securities to the books and records of the Funds
and the Custodian;
(5) Inspection of documentation of all repurchase agreements and underlying
collateral with brokers/banks records; and
(6) Tests of selected security transactions since the date of our last report.
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
the specified requirements.
In our opinion, management's assertion that the Riggs Funds complied with the
requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company
Act of 1940 as of April 30, 2003, with respect to securities reflected in the
investment accounts of the Riggs Funds, are fairly stated, in all material
respects.
This report is intended solely for the information and use of management, the
Board of Trustees of the Riggs Funds as listed in Appendix A and the Securities
and Exchange Commission, and is not intended to be and should not be used by
anyone other than these specified parties.
/s/ KPMG LLP
Boston, Massachusetts
June 11, 2003