Deloitte & Touche LLP – ‘40-17F2’ on 10/20/23 re: Northern Funds

On:  Friday, 10/20/23, at 1:55pm ET   ·   Effective:  10/20/23   ·   Accession #:  1050269-23-15   ·   File #:  811-08236

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Certificate of Accounting of Securities in the Custody of an Investment Company   —   Form N-17f-2   —   Rule 17f-2   —   ICA’40

Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 40-17F2     Certificate of Accounting of Securities in the         5±    20K 
                Custody of an Investment Company                                 


UNITED STATES                                                                   
SECURITIES AND EXCHANGE COMMISSION                                              
Washington, D.C.  20549                                                         
                                       -----------------------------
FORM N-17f-2                                        OMB Approval                
                                       -----------------------------
Certificate of Accounting of Securities and  OMB Number:         3235-0360      
Similar Investments in the Custody           Expires:         Feb 29, 2024      
of Management Investment Companies           Estimate average burden hours      
                                         per response . . . . . 2.00

Pursuant to Rule 17f-2 [17 CFR 270.17f-2]    -----------------------------      

-----------------------------------------------------------------------------   
1. Investment Company Act File Number:        Date examination completed:       

811-08236                                         April 30, 2023                

-----------------------------------------------------------------------------   
2. State Identification Number: IL                                              

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 name of investment company as specified in registration statement:     

Northern Funds                                                                  
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4. Address of principal executive office (number,street,city,state,zip code):   

50 South La Salle, Chicago, IL 60603                                            

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INDEPENDENT ACCOUNTANTS' REPORT                                                 

To the Board of Trustees of Northern Funds                                      

We have examined management's assertion, included in the accompanying           
Management's Statement Regarding Northern Funds' Compliance with Rule           
17f-2 Under the Investment Company Act of 1940, that Northern Funds             
(collectively, the "Company"), comprised of the funds listed in the             
Appendix A, complied with the requirements of subsections (b) and (c) of        
Rule 17f-2 of the Investment Company Act of 1940 (the "specified                
requirements") as of April 30, 2023, with respect to securities                 
reflected in the investment account of the Company. The Company's               
management is responsible for its assertion. Our responsibility is to           
express an opinion on management's assertion about the Company's                
compliance with the specified requirements based on our examination.            

Our examination was conducted in accordance with attestation standards          
established by the American Institute of Certified Public Accountants.          
Those standards require that we plan and perform the examination to             
obtain reasonable assurance about whether management's assertion about          
compliance with the specified requirements is fairly stated, in all             
material respects. An examination involves performing procedures to             
obtain evidence about management's assertion. The nature, timing, and           
extent of the procedures selected depend on our judgment, including an          
assessment of the risks of material misstatement of management's                
assertion, whether due to fraud or error. We believe that the evidence          
we obtained is sufficient and appropriate to provide a reasonable basis         
for our opinion.                                                                

We are required to be independent and to meet our other ethical                 
responsibilities in accordance with relevant ethical requirements               
relating to the engagement.                                                     

Included among our procedures were the following tests performed as of          
April 30, 2023, and with respect to agreement of security purchases and         
sales, for the period from March 31, 2023 (the date of our last                 
examination), through April 30, 2023, which is a date we selected               
without prior notice to management:                                             

1. Confirmation of all securities held by institutions in book entry            
form on behalf of Northern Trust, by the Federal Reserve Bank of Kansas City    
and The Depository Trust Company.                                               

2. Confirmation of 13 out of 17 securities pledged as collateral for future     
contracts with brokers. For confirms not received, agreed to the cash           
records provided by Northern Trust.                                             

3. Reconciliation of all such securities to the books and records of the        
Company and Northern Trust.                                                     

4. Confirmation and verification through a review of documents or electronic    
files provided by Northern Trust or verification of the subsequent              
settlement to cash records provided by Northern Trust of approximately 76% of   
all securities held in book entry form by various sub-custodians, by various    
agent banks, by Clearing and Depository Services, or by CREST Co.               

5. Confirmation of 16 out of 21 repurchase agreements with brokers/banks and    
agreement of underlying collateral with Northern Trust records. For             
confirmations not received, agreed to the cash records provided by Northern     
Trust.                                                                          

6. Agreement of 41 security purchases and 41 security sales or maturities       
since our last report from the books and records of the Company to the          
subsequent settlement in cash records provided by Northern Trust.               

Our examination does not provide a legal determination on the Company's         
compliance with specified requirements.                                         

In our opinion, management's assertion that the Northern 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, 2023 with respect to securities             
reflected in the investment account of the Company is fairly stated, in all     
material respects.                                                              

This report is intended solely for the information and use of management and    
the Board of Trustees of Northern Funds and the U.S. Securities and Exchange    
Commission and is not intended to be, and should not be, used by anyone         
other than these specified parties.                                             

/s/ DELOITTE & TOUCHE LLP                                                       

Chicago, Illinois                                                               
October 20, 2023                                                                

Appendix A                                                                      

Northern Funds                                                                  

Active M Emerging Markets Equity Fund                                           
Active M International Equity Fund                                              
Arizona Tax-Exempt Fund                                                         
Bond Index Fund                                                                 
California Intermediate Tax-Exempt Fund                                         
California Tax-Exempt Fund                                                      
Core Bond Fund                                                                  
Emerging Markets Equity Index Fund                                              
Fixed Income Fund                                                               
Global Real Estate Index Fund                                                   
Global Sustainability Index Fund                                                
Global Tactical Asset Allocation Fund                                           
High Yield Fixed Income Fund                                                    
High Yield Municipal Fund                                                       
Income Equity Fund                                                              
Intermediate Tax-Exempt Fund                                                    
International Equity Fund                                                       
International Equity Index Fund                                                 
Large Cap Core Fund                                                             
Large Cap Value Fund                                                            
Limited Term Tax-Exempt Fund                                                    
Limited Term U.S. Government Fund                                               
Mid Cap Index Fund                                                              
Multi-Manager Emerging Markets Debt Opportunity Fund                            
Multi-Manager Global Listed Infrastructure Fund                                 
Multi-Manager Global Real Estate Fund                                           
Multi Manager High Yield Opportunity Fund                                       
Northern Engage360 Fund                                                         
Short Bond Fund                                                                 
Small Cap Core Fund                                                             
Small Cap Index Fund                                                            
Small Cap Value Fund                                                            
Stock Index Fund                                                                
Tax-Advantaged Ultra-Short Fixed Income Fund                                    
Tax-Exempt Fund                                                                 
U.S. Government Fund                                                            
U.S. Government Money Market Fund                                               
U.S. Government Select Money Market Fund                                        
U.S. Treasury Index Fund                                                        
U.S. Quality ESG Fund                                                           
Ultra-Short Fixed Income Fund                                                   

Management Statement Regarding Northern Funds' Compliance with Rule 17f-2       
Under the Investment Company Act of 1940                                        

We, as members of management of Northern Funds (collectively, the "Company"),   
comprised of the funds listed in the attached Appendix A, 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 Company's compliance       
with the requirements of subsections (b) and (c) of Rule 17f-2 as of April      
30, 2023, and from March 31, 2023 (the date of your last examination)           
through April 30, 2023.                                                         

Based on this evaluation, we assert that the Company was 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, 2023, and from March 31, 2023 (the date     
of your last examination) through April 30, 2023, with respect to securities    
reflected in the investment accounts of the Company.                            

Northern Funds                                                                  

By:                                                                             

/s/ Peter Ewing                                                                 
Peter Ewing                                                                     
President, Northern Funds                                                       

/s/ Randal Rein                                                                 
Randal Rein                                                                     
Treasurer, Northern Funds                                                       

October 20, 2023                                                                

Appendix A                                                                      

Northern Funds                                                                  

Active M Emerging Markets Equity Fund                                           
Active M International Equity Fund                                              
Arizona Tax-Exempt Fund                                                         
Bond Index Fund                                                                 
California Intermediate Tax-Exempt Fund                                         
California Tax-Exempt Fund                                                      
Core Bond Fund                                                                  
Emerging Markets Equity Index Fund                                              
Fixed Income Fund                                                               
Global Real Estate Index Fund                                                   
Global Sustainability Index Fund                                                
Global Tactical Asset Allocation Fund                                           
High Yield Fixed Income Fund                                                    
High Yield Municipal Fund                                                       
Income Equity Fund                                                              
Intermediate Tax-Exempt Fund                                                    
International Equity Fund                                                       
International Equity Index Fund                                                 
Large Cap Core Fund                                                             
Large Cap Value Fund                                                            
Limited Term Tax-Exempt Fund                                                    
Limited Term U.S. Government Fund                                               
Mid Cap Index Fund                                                              
Multi-Manager Emerging Markets Debt Opportunity Fund                            
Multi-Manager Global Listed Infrastructure Fund                                 
Multi-Manager Global Real Estate Fund                                           
Multi Manager High Yield Opportunity Fund                                       
Northern Engage360 Fund                                                         
Short Bond Fund                                                                 
Small Cap Core Fund                                                             
Small Cap Index Fund                                                            
Small Cap Value Fund                                                            
Stock Index Fund                                                                
Tax-Advantaged Ultra-Short Fixed Income Fund                                    
Tax-Exempt Fund                                                                 
U.S. Government Fund                                                            
U.S. Government Money Market Fund                                               
U.S. Government Select Money Market Fund                                        
U.S. Treasury Index Fund                                                        
U.S. Quality ESG Fund                                                           
Ultra-Short Fixed Income Fund                                                   

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘40-17F2’ Filing		Date		Other Filings
Filed on / Effective on:		10/20/23
		4/30/23		N-MFP2
		3/31/23		24F-2NT,  N-CEN,  N-CSR,  N-MFP2,  NPORT-P
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