HOUGH GROUP OF FUNDS
For six-month period ending 10/31/03
File Number 811-7902


N-CSR Item 9. Controls and Procedures

(a)	Based on an evaluation of the disclosure controls and procedures
(as defined in rule 30a-2(c) under the Act), the Principal Executive Officer
and Treasurer of the Trust have concluded that such disclosure controls and
procedures are effectively designed to ensure that information required to be
disclosed by the Trust is accumulated and communicated to the Trust's
management to allow timely decisions regarding required disclosure.

 (b)	There were no significant changes in the registrant's internal
controls or in other factors that could significantly affect these controls
subsequent to the date of their evaluation, including any corrective actions
with regard to significant deficiencies and material weaknesses.

N-CSR Item 10. Exhibits


(b)		CERTIFICATION OF PRINCIPAL EXECUTIVE OFFICER

I, W. Robb Hough, Jr., certify that:

1. I have reviewed this report on Form N-CSR of The Hough Group of Funds;

2. Based on my knowledge, this report does not contain any untrue statement
of a material fact or omit to state a material fact necessary to make the
statements made, in light of the circumstances under which such statements
were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial information included in this report,
and the financial statements on which the financial information is based,
fairly present in all material respects the financial condition, results of
operations, changes in net assets, and cash flows (if the financial
statements are required to include a statement of cash flows) of the
registrant as of, and for, the periods presented in this report;

4. The registrant's other certifying officers and I are responsible for
establishing and maintaining disclosure controls and procedures
(as defined in rule 30a-2(c) under the Investment Company Act) for the
registrant and have:

	a) designed such disclosure controls and procedures to ensure that
material information relating to the registrant, including its consolidated
subsidiaries, is made known to us by others within those entities,
particularly during the period in which this report is being prepared;

	b) evaluated the effectiveness of the registrant's disclosure
controls and procedures as of a date within 90 days prior to the filing
date of this report (the "Evaluation Date"); and

	c) presented in this report our conclusions about the effectiveness
of the disclosure controls and procedures based on our evaluation as of the
Evaluation Date;

5. The registrant's other certifying officers and I have disclosed, based on
our most recent evaluation, to the registrant's auditors and the audit
committee of the registrant's board of directors (or persons performing
the equivalent functions):

	a) all significant deficiencies in the design or operation of
internal controls which could adversely affect the registrant's ability to
record, process, summarize, and report financial data and have identified for
the registrant's auditors any material weaknesses in internal controls; and

	b) any fraud, whether or not material, that involves management or
other employees who have a significant role in the registrant's internal
controls; and

6. The registrant's other certifying officers and I have indicated in this
report whether or not there were significant changes in internal controls or
in other factors that could significantly affect internal controls subsequent
to the date of our most recent evaluation, including any corrective actions,
with regard to significant deficiencies and material weaknesses.

December 29, 2003


/s/W. ROBB HOUGH, JR.

W. Robb Hough, Jr.
President and Chairman of the Board of Trustees
Chief Executive Officer




(b)		CERTIFICATION OF PRINCIPAL FINANCIAL OFFICER


I, John W. Waechter, certify that:

1. I have reviewed this report on Form N-CSR of The Hough Group of Funds;

2. Based on my knowledge, this report does not contain any untrue statement
of a material fact or omit to state a material fact necessary to make the
statements made, in light of the circumstances under which such statements
were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial information included in this report,
and the financial statements on which the financial information is based,
fairly present in all material respects the financial condition, results of
operations, changes in net assets, and cash flows (if the financial
statements are required to include a statement of cash flows) of the
registrant as of, and for, the periods presented in this report;

4. The registrant's other certifying officers and I are responsible for
establishing and maintaining disclosure controls and procedures (as defined
in Rule 30a-2(c) under the Investment Company Act) for the registrant
and have:

	a) designed such disclosure controls and procedures to ensure that
material information relating to the registrant, including its consolidated .
subsidiaries, is made known to us by others within those entities,
particularly during the period in which this report is being prepared;

	b) evaluated the effectiveness of the registrant's disclosure
controls and procedures as of a date within 90 days prior to the filing
date of this report (the "Evaluation Date"); and

	c) presented in this report our conclusions about the effectiveness
of the disclosure controls and procedures based on our evaluation as of the
Evaluation Date;

5. The registrant's other certifying officers and I have disclosed, based on
our most recent evaluation, to the registrant's auditors and the audit
committee of the registrant's board of directors (or persons performing the
equivalent functions):

	a) all significant deficiencies in the design or operation of
internal controls which could adversely affect the registrant's ability to
record, process, summarize, and report financial data and have identified
for the registrant's auditors any material weaknesses in internal
controls; and

	b) any fraud, whether or not material, that involves management or
other employees who have a significant role in the registrant's internal
controls; and

6. The registrant's other certifying officers and I have indicated in this
report whether or not there were significant changes in internal controls
or in other factors that could significantly affect internal controls
subsequent to the date of our most recent evaluation, including any
corrective actions, with regard to significant deficiencies and
material weaknesses.

December 29, 2003

/s/JOHN W. WAECHTER

John W. Waechter
Treasurer and Chief Financial Officer