WM STRATEGIC ASSET MANAGEMENT PORTFOLIOS
NSAR-B, EX-99, 2000-12-29
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INDEPENDENT AUDITORS' REPORT




To the Trustees and Shareholders of WM Strategic Growth Portfolio,
WM Conservative Growth Portfolio, WM Balanced Portfolio,
WM Conservative Balanced Portfolio and WM Flexible Income Portfolio:

In planning and performing our audits of the financial statements of
WM Strategic Growth Portfolio, WM Conservative Growth Portfolio,
WM Balanced Portfolio, WM Conservative Balanced Portfolio (formerly
known as WM Income Portfolio) and WM Flexible Income Portfolio
(collectively the "Portfolios") for the year ended October 31, 2000
(on which we have issued our report dated December 8, 2000), we considered
their internal control, including control activities for safeguarding
securities, in order to determine our auditing procedures for the purpose of
expressing our opinion on the financial statements and to comply
with the requirements of Form N-SAR, and not to provide assurance on the
Portfolios' internal control.
The management of the Portfolios is responsible for establishing and maintaining
internal control. In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and related costs of
controls.  Generally, controls that are relevant to an audit pertain to the
entity's objective of preparing financial statements for external purposes that
are fairly presented in conformity with generally accepted accounting
principles generally accepted in the United States of America.
Those controls include the safeguarding of assets against unauthorized
acquisition, use, or disposition.
	Because of inherent limitations in any internal control, misstatements due to
error or fraud may occur and not be detected.  Also, projections of any
evaluation of internal control to future periods are subject to the risk that
the internal control may become inadequate because of changes in conditions or
that the degree of compliance with policies or procedures may deteriorate.
	Our consideration of the Portfolios' internal control would not necessarily
disclose all matters in internal control that might be material weaknesses
under standards established by the American Institute of Certified Public
Accountants.  A material weakness is a condition in which the
design or operation of one or more of the internal control components does not
reduce to a relatively low level the risk that misstatements due to error or
fraud in amounts that would be material in relation to the financial statements
being audited may occur and not be detected within a timely period by employees
in the normal course of performing their assigned functions.  However, we noted
no matters involving the Portfolios' internal control and its operation,
including controls for safeguarding securities that we consider to be material
weaknesses as defined above as of October 31, 2000.
	This report is intended solely for the information and use of management,
the Trustees and Shareholders of the Portfolios, and the Securities and
Exchange Commission and is not intended to be and should not be used by
anyone other than these specified parties.



DELOITTE & TOUCHE LLP
San Francisco, CA

	December 8, 2000



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