Report of Independent Registered Public Accounting Firm
To the Shareholders and
Board of Trustees of USAA Mutual Funds Trust
In planning and performing our audits of the financial statements of
USAA Mutual Funds Trust (comprising USAA Aggressive Growth Fund, USAA
Growth Fund, USAA Income Stock Fund, USAA Growth & Income Fund, USAA
Science & Technology Fund, USAA Small Cap Stock Fund, USAA Capital
Growth Fund, USAA Value Fund, USAA Income Fund, USAA Short-Term Bond
Fund, USAA High Income Fund, USAA Intermediate-Term Bond Fund, and USAA
Money Market Fund) (the Trust) as of and for the year ended July 31, 2020,
in accordance with the standards of the Public Company Accounting
Oversight Board (United States), we considered the Trust's internal
control over financial reporting, including controls over safeguarding
securities, as a basis for designing our auditing procedures for the
purpose of expressing our opinion on the financial statements and to
comply with the requirements of Form N-CEN, but not for the purpose of
expressing an opinion on the effectiveness of the Trust's internal
control over financial reporting. Accordingly, we express no such opinion.
The management of the Trust is responsible for establishing and
maintaining effective internal control over financial reporting.
In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and related
costs of controls. A trust's internal control over financial reporting
is a process designed to provide reasonable assurance regarding the
reliability of financial reporting and the preparation of financial
statements for external purposes in accordance with U.S. generally
accepted accounting principles. A trust's internal control over
financial reporting includes those policies and procedures that (1)
pertain to the maintenance of records that, in reasonable detail,
accurately and fairly reflect the transactions and dispositions of
the assets of the trust; (2) provide reasonable assurance that transactions
are recorded as necessary to permit preparation of financial statements
in accordance with U.S. generally accepted accounting principles, and that
receipts and expenditures of the trust are being made only in accordance
with authorizations of management and trustees of the trust; and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a trust's assets that could
have a material effect on the financial statements.
Because of its inherent limitations, internal control over financial
reporting may not prevent or detect misstatements. Also, projections of any
evaluation of effectiveness to future periods are subject to the risk that
controls may become inadequate because of changes in conditions, or that
the degree of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists when the
design or operation of a control does not allow management or employees,
in the normal course of performing their assigned functions, to prevent or
detect misstatements on a timely basis. A material weakness is a deficiency,
or a combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a material
misstatement of the trust's annual or interim financial statements will not
be prevented or detected on a timely basis.
Our consideration of the Trust's internal control over financial reporting
was for the limited purpose described in the first paragraph and would not
necessarily disclose all deficiencies in internal control that might be
material weaknesses under standards established by the Public Company
Accounting Oversight Board (United States). However, we noted no deficiencies
in the Trust's internal control over financial reporting and its operation,
including controls over safeguarding securities, that we consider to be a
material weakness as defined above as of July 31, 2020.
This report is intended solely for the information and use of management and
the Board of Trustees of the 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.
/s/ Ernst & Young LLP
San Antonio, TX
September 29, 2020