Kobren Insight Funds – ‘40-17F1/A’ on 3/23/99

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Amendment to Certificate of Accounting of Securities in the Custody of a Management Investment Company   —   Form N-17F-1
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 40-17F1/A   Report Pursuant to Rule 17F-1                          6     22K 

40-17F1/A
1st Page of 6
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Independent Auditor's Report

     To The Board of Directors of the Kobren  Insight Group of Funds  consisting
of the Growth, Moderate Growth and Conservative Allocation Funds (the "Funds"): 

     We have examined  management's  assertion about the Funds'  compliance with
the requirements of Rule 17f-1 of the Investment Company Act of 1940, as amended
(the Act) as of  December  31,  1998,  included in the  accompanying  Management
Statement Regarding Compliance with Certain Provisions of the Investment Company
Act of 1940.  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 made in accordance  with 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 December 31, 1998,  and from  November 30, 1998 (the date of our
last exam), through December 31, 1998:                                          

     -  Confirmation  of all  securities  held by  National  Financial  Services
Corporation in book entry form;                                 

     - 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;                                        

     - Tests of security purchases and sales or maturities since our last report
  from the books and records of the Funds to authorized trade tickets.

     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 Funds were in compliance
with the  requirements  of Rule 17f-1 of the Investment  Company Act of 1940, as
amended (the Act) as of December 31, 1998, with respect to securities  reflected
in the  investment  accounts  of the Funds are fairly  stated,  in all  material
respects.                                                                       

     This report is intended solely for the information and use of management of
the Funds and the Securities and Exchange  Commission and should not be used for
any other purpose.                                                              

Boston, Massachusetts                                                           
March 18, 1999                                                                  

40-17F1/A
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 Management Statement Regarding Compliance With Certain Provisions
of the Investment Company Act of 1940 

     We,  as  members  of  management  of the  Kobren  Insight  Group  of  Funds
(consisting of the Growth,  Moderate Growth and Conservative  Allocation  Funds)
(the "Funds") are responsible for complying with the  requirements of Rule 17f-1
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 Rule 17f-1 as of December 31, 1998,  and from November 30, 1998
(the date of our last assertion), through December 31, 1998.                    

     Based on this evaluation, except for the compliance deficiencies identified
in the March 2, 1999  letter to Eric M. Kobren from Daniel B. Wong of the Boston
District  Office of the  Securities  & Exchange  Commission,  we assert that the
Funds  were in  compliance  with the  requirements  of  17f-1 of the  Investment
Company Act of 1940,  as of December 31, 1998,  and from  November 30, 1998 (the
date of our last assertion), through December 31,1998 with respect to securities
reflected in the investment accounts of the Funds.                              

The Kobren Group of Funds                                                       

By:      /s/ ERIC GODES                                                         
ERIC GODES                                                    
Vice President                                                
(Title)                                                       
03/18/99                                                      
(Date)                                                        

40-17F1/A
3rd Page of 6
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Just 3rd
Independent Auditor's Report

     To The Board of Directors of the Kobren  Insight Group of Funds  consisting
of the Growth, Moderate Growth and Conservative Allocation Funds (the "Funds"): 

     We have examined  management's  assertion about the Funds'  compliance with
the requirements of Rule 17f-1 of the Investment Company Act of 1940, as amended
(the Act) as of  November  30,  1998,  included in the  accompanying  Management
Statement Regarding Compliance with Certain Provisions of the Investment Company
Act of 1940.  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 made in accordance  with 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 November 30, 1998,  and from June 30, 1998 (the date of our last
exam), through November 30, 1998:                                               

     -  Confirmation  of all  securities  held by  National  Financial  Services
Corporation in book entry form;                                 

     - 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;                                        

     - Tests of security purchases and sales or maturities since our last report
  from the books and records of the Funds to authorized trade tickets.

     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 Funds were in compliance
with the  requirements  of Rule 17f-1 of the Investment  Company Act of 1940, as
amended (the Act) as of November 30, 1998, with respect to securities  reflected
in the  investment  accounts  of the Funds are fairly  stated,  in all  material
respects.                                                                       

     This report is intended solely for the information and use of management of
the Funds and the Securities and Exchange  Commission and should not be used for
any other purpose.                                                              

Boston, Massachusetts                                                           
March 18, 1999                                                                  

40-17F1/A
4th Page of 6
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Just 4th
 Management Statement Regarding Compliance With Certain Provisions
of the Investment Company Act of 1940 

     We,  as  members  of  management  of the  Kobren  Insight  Group  of  Funds
(consisting of the Growth,  Moderate Growth and Conservative  Allocation  Funds)
(the "Funds") are responsible for complying with the  requirements of Rule 17f-1
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 Rule 17f-1 as of November 30, 1998, and from June 30, 1998 (the
date of our last assertion), through November 30, 1998.                         

     Based on this evaluation, except for the compliance deficiencies identified
in the March 2, 1999  letter to Eric M. Kobren from Daniel B. Wong of the Boston
District  Office of the  Securities  & Exchange  Commission,  we assert that the
Funds  were in  compliance  with the  requirements  of  17f-1 of the  Investment
Company Act of 1940,  as of November 30, 1998,  and from June 30, 1998 (the date
of our last  assertion),  through  November  30,1998 with respect to  securities
reflected in the investment accounts of the Funds.                              

The Kobren Group of Funds                                                       

By:      /s/ ERIC GODES                                                         
ERIC GODES                                                    
Vice President                                                
(Title)                                                       
03/18/99                                                      
(Date)                                                        

40-17F1/A
5th Page of 6
TOC
1st
Previous
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Just 5th
Independent Auditor's Report

     To The Board of Directors of the Kobren  Insight Group of Funds  consisting
of the Growth, Moderate Growth and Conservative Allocation Funds (the "Funds"): 

     We have examined  management's  assertion about the Funds'  compliance with
the requirements of Rule 17f-1 of the Investment Company Act of 1940, as amended
(the Act) as of June 30, 1998, included in the accompanying Management Statement
Regarding  Compliance with Certain  Provisions of the Investment  Company Act of
1940.   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 made in accordance  with 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 June 30,  1998,  and from  January  8,  1998  (the  date of the
establishment   of  the  Funds   contract  with  National   Financial   Services
Corporation), through June 30, 1998:                                            

     -  Confirmation  of all  securities  held by  National  Financial  Services
Corporation in book entry form;                                 

     - 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;                                        

     - Tests of security purchases and sales or maturities since January 8, 1998
  from the books and records of the Funds to authorized trade tickets.

     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 Funds were in compliance
with the  requirements  of Rule 17f-1 of the Investment  Company Act of 1940, as
amended (the Act) as of June 30, 1998,  with respect to securities  reflected in
the  investment  accounts  of the  Funds  are  fairly  stated,  in all  material
respects.                                                                       

     This report is intended solely for the information and use of management of
the Funds and the Securities and Exchange  Commission and should not be used for
any other purpose.                                                              

Boston, Massachusetts                                                           
March 18, 1999                                                                  

40-17F1/A
Last Page of 6
TOC
1st
Previous
Next
↓Bottom
Just 6th
Management Statement Regarding Compliance With Certain Provisions 
of the Investment Company Act of 1940 

     We,  as  members  of  management  of the  Kobren  Insight  Group  of  Funds
(consisting of the Growth,  Moderate Growth and Conservative  Allocation  Funds)
(the "Funds") are responsible for complying with the  requirements of Rule 17f-1
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 Rule 17f-1 as of June 30,  1998,  and from January 8, 1998 (the
date  of the  establishment  of the  Funds'  contract  with  National  Financial
Services Corporation), through June 30, 1998.                                   

     Based on this evaluation, except for the compliance deficiencies identified
in the March 2, 1999  letter to Eric M. Kobren from Daniel B. Wong of the Boston
District  Office of the  Securities  & Exchange  Commission,  we assert that the
Funds  were in  compliance  with the  requirements  of  17f-1 of the  Investment
Company Act of 1940, as of June 30, 1998,  and from January 8, 1998 (the date of
the  establishment  of the Funds'  contract  with  National  Financial  Services
Corporation),  through June 30, 1998 with respect to securities reflected in the
investment accounts of the Funds.                                               

The Kobren Group of Funds                                                       

By:      /s/ ERIC GODES                                                         
ERIC GODES                                                    
Vice President                                                
(Title)                                                       
03/18/99                                                      
(Date)                                                        

Dates Referenced Herein   and   Documents Incorporated by Reference

				Referenced-On Page
This ‘40-17F1/A’ Filing		Date		First		Last			Other Filings
Filed on:		3/23/99							40-17F1
		3/18/99		1		5
		3/2/99		2		6
		12/31/98		1		2			24F-2NT,  N-30D,  NSAR-B
		11/30/98		1		4			485APOS
		6/30/98		3		6			N-30B-2,  NSAR-A
		1/8/98		5		6
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