40-17F2 1 c100860_4017f2.htm

UNITED STATES

 

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: 811-07912
  
 Date examination completed: September 10, 2020
  
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 D03721305 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:
   
  Old Westbury Funds, Inc.
   
4. Address of principal executive office:
   
  760 Moore Road, King of Prussia, Pennsylvania 19406
 

Management Statement Regarding Compliance With Certain Provisions of
the Investment Company Act of 1940

 

December 23, 2020

 

I, as a member of management of Old Westbury All Cap Core Fund, Old Westbury All Cap ESG Fund, Old Westbury California Municipal Bond Fund, Old Westbury Fixed Income Fund, Old Westbury Large Cap Strategies Fund, Old Westbury Municipal Bond Fund, Old Westbury New York Municipal Bond Fund, and Old Westbury Small & Mid Cap Strategies Fund (Martingale sleeve, Tax Managed sleeve, and U.S. Mid Cap sleeve) (collectively, the “Funds”), am 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 (the “Act”). I am also responsible for establishing and maintaining effective internal controls over compliance with those requirements. I have performed an evaluation of the Funds’ compliance with the requirements of subsections (b) and (c) of Rule 17f-2 as of September 10, 2020 and from August 5, 2020 (date of last examination) through September 10, 2020.

 

Based on this evaluation, I assert that the Funds were in compliance with the requirements of subsections (b) and (c) of Rule 17f-2 of the Act as of September 10, 2020 and from August 5, 2020 (date of last examination) through September 10, 2020, with respect to securities reflected in the investment account of the Funds.

 

By: /s/ Matthew Rizzi  
     
     
  Matthew Rizzi  
     
  Old Westbury Funds, Inc.  
     
  Vice President & Treasurer  
 

 

Report of Independent Registered Public Accounting Firm

 

To the Board of Directors of Old Westbury Funds, Inc.

 

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 Old Westbury Funds, Inc. (comprising, respectively, Old Westbury All Cap Core Fund, Old Westbury All Cap ESG Fund, Old Westbury California Municipal Bond Fund, Old Westbury Fixed Income Fund, Old Westbury Large Cap Strategies Fund, Old Westbury Municipal Bond Fund, Old Westbury New York Municipal Bond Fund, and Old Westbury Small & Mid Cap Strategies Fund (Martingale sleeve, Tax Managed sleeve, and U.S. Mid Cap sleeve) (collectively, the “Funds”) complied with the requirements of subsections (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 (the “Act”) as of September 10, 2020. 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 the standards of the Public Company Accounting Oversight Board (United States) 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 September 10, 2020 and with respect to agreement of security purchases and sales, for the period from August 5, 2020 (the date of our last examination) through September 10, 2020:

 

Confirmation of all securities held by Bank of New York Mellon, Federated Shareholder Services Company, and SEI Investments Company in book entry form;
   
Reconciliation of such confirmations to the books and records of the Funds and the custodian;
   
Agreement of pending purchase activity as of September 10, 2020 to documentation supporting corresponding subsequent cash payments and related settlements; and
   
Agreement of a total of five security purchases and five security sales across all Funds since our last examination from the books and records of the Funds to cash settlement per the bank statements.

 

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.

 

A member firm of Ernst & Young Global Limited

 

 

In our opinion, management’s assertion that the Funds complied with the requirements of subsections (b) and (c) of Rule 17f-2 of the Act as of September 10, 2020, with respect to securities, 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 management and the Board of Directors of Old Westbury Funds, Inc. and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.

 

 

New York, New York
December 23, 2020

 

A member firm of Ernst & Young Global Limited