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UNITED STATES |
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SECURITIES AND EXCHANGE COMMISSION |
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Washington, D.C. 20549 |
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OMB APPROVAL |
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FORM N-17f-2 |
OMB Number: |
3235-0360 |
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Expires: |
April 30, 2012 |
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Certificate of Accounting of Securities and Similar |
Estimated average burden |
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Investments in the Custody of |
hours per response............2.0 |
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Management Investment Companies |
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Pursuant to Rule 17f-2 [17 CFR 270.17f-2] |
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1. Investment Company Act
File Number: |
Date examination completed: |
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2. State identification Number: N/A |
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AL |
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AR |
CA |
CO |
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CT |
DE |
DC |
FL |
GA |
HI |
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ID |
IL |
IN |
IA |
KS |
KY |
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LA |
ME |
MD |
MA |
MI |
MN |
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MS |
MO |
MT |
NE |
NV |
NH |
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NJ |
NM |
NY |
NC |
ND |
OH |
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OK |
OR |
PA |
RI |
SC |
SD |
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TN |
TX |
UT |
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VA |
WA |
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WV |
WI |
WY |
PUERTO RICO |
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Other (specify): |
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3. Exact name of investment company as specified in
registration statement: |
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4. Address of principal executive office (number,
street, city, state, zip code): |
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INSTRUCTIONS
This Form must be completed by 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
SEC2198 (10-03)
SEC’s Collection of Information
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. Filing of Form N-17f-2 is mandatory for an investment company that has custody of securities or similar investments. Rule 17f-2 under section 17(f) of the Investment Company Act of 1940 requires the investment company to retain an independent public accountant to verify the company’s securities and similar investments by actual examination three times during each fiscal year. The accountant must prepare a certificate stating that the examination has occurred and describing the examination, and must transmit the certificate to the Commission with Form N-17f-2 as a cover sheet. The Commission uses the Form to ensure that the certificate is properly attributed to the investment company. The Commission estimates that the burden of completing Form N-17f-2 is approximately 1.0 hours per filing. Any member of the public may direct to the Commission any comments concerning the accuracy of the burden estimate of this Form, and any suggestions for reducing this burden. This collection of information has been reviewed by the Office of Management and Budget in accordance with the clearance requirements of 44 U.S.C. § 3507. Responses to this collection of information will not be kept confidential.
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KPMG LLP |
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617 988 1000 |
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99 High Street |
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617 507 8321 |
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Boston, MA 02110-2371 |
Internet |
www.us.kpmg.com |
Report of Independent Registered Public Accounting Firm
To the Board of Trustees
ING Global Advantage and Premium Opportunity Fund
We have examined management’s assertion, included in the accompanying Management Statement Regarding Compliance with Certain Provisions of the Investment Company Act of 1940 (the Act), that ING Global Advantage and Premium Opportunity (the Fund), complied with the applicable requirements of subsections (b) and (c) of rule 17f-2 under the Act with respect to the securities held by affiliated sub-custodian banks pursuant to rule 17f-5 of the Act as of May 31, 2008, June 30, 2008, and August 31, 2008. Management is responsible for the Fund’s compliance with those requirements. Our responsibility is to express an opinion on management’s assertion about the Fund’s compliance based on our examinations.
Our examinations were 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 Fund’s 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 May 31, 2008, June 30, 2008, and August 31, 2008, and, with respect to agreement of security purchases and sales, for the period October 31, 2007 through August 31, 2008:
(1) Confirmation of all securities held in book entry form by the Bank of New York Mellon (formerly, The Bank of New York) (custodian);
(2) Confirmation of securities held in book entry form by ING Belgium S.A./N.V. (affiliated sub-custodian bank);
(3) Confirmation of securities held in book entry form by Euroclear Belgium (foreign depository);
(4) Confirmation or 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;
(5) Reconciliation of all such securities to the books and records of the Fund, the custodian and the affiliated sub-custodian bank;
(6) Agreement of selected security purchases and sales during the period October 31, 2007 through August 31, 2008 from the books and records of the Fund to broker confirmations or bank statements.
We believe that our examinations provide a reasonable basis for our opinion. Our examinations do not provide a legal determination on the Fund’s compliance with the specified requirements.
In our opinion, management’s assertion that the Fund complied with the applicable requirements of subsections (b) and (c) of rule 17f-2 of the Act as of May 31, 2008, June 30, 2008, and August 31, 2008, with respect to the securities reflected in the investment accounts of the Fund that are held by the affiliated sub-custodian banks pursuant to rule 17f-5 of the Act, is fairly stated, in all material respects. We have not examined the Fund’s compliance with rule 17f-5 of the Act and express no opinion thereon.
KPMG LLP, a U.S. limited liability partnership, is the U.S.
member firm of KPMG International, a Swiss cooperative.
This report is intended solely for the information and use of management, the Board of Trustees of the Fund and the Securities and Exchange Commission, and is not intended to be and should not be used by anyone other than these specified parties.
Boston, Massachusetts
August 14, 2009
November 10, 2008
KPMG LLP
Attention: Matt Giordano
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 ING Funds listed in Appendix A (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 Company,” 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 May 31, 2008, June 30, 2008, and August 31, 2008, and for the period from November 1, 2007 through August 31, 2008.
Based on this evaluation, we assert that the Funds were in compliance with the applicable requirements of subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 as of May 31, 2008, June 30, 2008, and August 31, 2008, and for the period from November 1, 2007 through August 31, 2008, with respect to securities reflected in the investment accounts of the Funds that are held by affiliated foreign sub-custodians. We note that all affiliated sub-custodians that maintained assets of the Funds during the applicable period qualified as “Eligible Foreign Custodians” under rule 17f-5.
Very truly yours,
ING Funds
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/s/ Shaun P. Mathews |
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Shaun P. Mathews |
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Chief Executive Officer |
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/s/ Todd Modic |
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Todd Modic |
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Senior Vice President and Chief Financial Officer |
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7337 East Doubletree Ranch Road |
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Scottsdale, AZ 85258-2034 |
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Toll Free: 800.745.4746 |
Appendix A
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ING JPMorgan Emerging Markets Equity Portfolio |
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ING FMR Diversified MidCap Portfolio |
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ING Focus 5 Portfolio |
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ING International Growth Opportunities Portfolio |
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ING Global Real Estate Portfolio |
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ING Janus Contrarian Portfolio |
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ING Julius Baer Foreign Portfolio |
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ING MFS Utilities Portfolio |
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ING Multi-Manager International Small Cap Portfolio |
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ING VP Index Plus International Equity Portfolio |
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ING Disciplined International SmallCap Fund |
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ING Emerging Countries Fund |
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ING Emerging Markets Fixed Income Fund |
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ING European Real Estate Fund |
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ING Foreign Fund |
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ING Global Equity Dividend Fund |
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ING Global Real Estate Fund |
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ING Index Plus International Equity Fund |
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ING International Equity Dividend Fund |
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ING International Growth Opportunities Fund |
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ING International Real Estate Fund |
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ING International SmallCap Multi-Manager Fund |
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ING International Value Choice Fund |
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ING International Value Opportunities Fund |
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ING Russia Fund |
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ING Oppenheimer Strategic Income Portfolio |
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ING Global Advantage and Premium Opportunity Fund |
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ING International High Dividend Equity Income Fund |
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ING Wisdomtree Global High Yielding Equity Index Portfolio |
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ING International Index Portfolio |