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Form 40-17F1 Starboard Investment Filed by: Starboard Investment Trust

August 17, 2022 3:22 PM EDT

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549


FORM N-17f-1

          OMB APPROVAL         
Certificate of Accounting of Securities and Similar
OMB Number:
3235-0359
Investments of a Management Investment Company Expires:
May 31, 2021
in the Custody of Members of Estimated average burden
National Securities Exchanges hours per response
1.5
   
Pursuant to Rule 17f-1 [17 CFR 270.17f-1]



1. Investment Company Act File Number:
 
811-22298
Date examination completed:
 
May 31, 2022
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 name of investment company as specified in registration statement:   AI Quality Growth ETF, Adaptive Alpha Opportunities ETF, RH Tactical Outlook ETF, and RH Tactical Rotation ETF

 
4. Address of principal executive office (number, street, city, state, zip code):  116 South Franklin Street, Rocky Mount, NC  27804





INSTRUCTIONS

This Form must be completed by investment companies that place or maintain securities or similar investments in the custody of a company that is a member of a national securities exchange.

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-1 under the Act and applicable state law, examines securities and similar investments in the custody of a company that is a member of a national securities exchange.

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-1 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





SEC 2205 (11-03)


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-1 is mandatory for an investment company that maintains securities or similar investments in the custody of a member of a National Securities Exchange. Rule 17f-1 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-1 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-1 is approximately 0.16 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 the burden of the Form. 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.

MANAGEMENT STATEMENT REGARDING COMPLIANCE WITH CERTAIN PROVISIONS OF
THE INVESTMENT COMPANY ACT OF 1940



July 29, 2022


We, as members of management of AI Quality Growth ETF, Adaptive Alpha Opportunities ETF, RH Tactical Outlook ETF, and RH Tactical Rotation ETF, (the “Funds”), each a series of shares of beneficial interest in Starboard Investment Trust, are responsible for complying with the requirements of subsections (b)(1) and (b)(6) of Rule 17f-1, “Custody of Securities with Members of National Securities Exchanges,” 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)(1) and (b)(6) of Rule 17f-1 as of May 31, 2022 and from February 28, 2022 (the date of last examination), through May 31, 2022.

Based on this evaluation, we assert that the Funds were in compliance with the requirements of subsections (b)(1) and (b)(6) of Rule 17f-1 of the Investment Company Act of 1940 as of May 31, 2022, and from February 28, 2022 (the date of last examination), through May 31, 2022, with respect to securities reflected in the investment account of the Fund.


/s/ Katherine M. Honey
Katherine M. Honey, President and Principal Executive Officer, Starboard Investment Trust


/s/ Ashley H. Lanham
Ashley H. Lanham, Treasurer and Principal Financial Officer, Starboard Investment Trust






REPORT OF INDEPENDENT PUBLIC ACCOUNTANT


To the Board of Trustees of Starboard Investment Trust

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 AI Quality Growth ETF, Adaptive Alpha Opportunities ETF, RH Tactical Outlook ETF, and RH Tactical Rotation ETF (the “Funds”), each a series of shares of beneficial interest in Starboard Investment Trust, complied with the requirements of subsections (b)(1) and (b)(6) of Rule 17f-1 under the Investment Company Act of 1940 (the Act) as of May 31, 2022.  Management is responsible for its assertion about compliance with the requirements of subsections (b)(1) and (b)(6) of Rule 17f-1 of the Act (the “specified requirements”). Our responsibility is to express an opinion on management's assertion about the Funds’ 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 whether management's assertion is fairly stated in all material respects. 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.

Included among our procedures were the following tests performed as of May 31, 2022, and with respect to agreement of security purchase and sales, for the period from February 28, 2022 (the date of last examination), through May 31, 2022:


1.
Confirmation of securities held by a member of a national securities exchange (Clear Street) in the Funds’ name;

2.
Reconciliation of securities confirmed by the member of the national securities exchange (Clear Street) to books and records of the Funds;

3.
Test a sample of transactions since our last report from the books and records of the Funds to monthly Clear Street 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.

In our opinion, management’s assertion that AI Quality Growth ETF, Adaptive Growth Opportunities ETF, RH Tactical Outlook ETF and RH Tactical Rotation ETF complied, with the requirements of subsections (b)(1) and (b)(6) of Rule 17f-1 of the Investment Company Act of 1940 as of May 31, 2022, with respect to securities reflected in the investment account of the Funds are fairly stated, in all material respects.

This report is intended solely for the information and use of management and the Board of Trustees of Starboard Investment Trust and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.


BBD, LLP
Philadelphia, Pennsylvania
July 29, 2022



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