PIC MID CAP PORTFOLIO
NT-NSAR, 1999-12-30
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UNITED STATES SECURITIES AND EXCHANGE
COMMISSION
WASHINGTON, D.C. 20549
FORM 12b-25
NOTIFICATION OF LATE FILING

Commission File Number: 811-08593

(check one):   [  ] Form 10-K and Form 10-KSB
                       [ ] Form 10-Q and   Form 10-QSB
                       [ ] Form 20-F       [ ]  Form 11-K
                      [x ] Form N-SAR
For Period Ended: October 31, 1999

[ ] Transition Report on Form 10-K
[ ] Transition Report on Form 20-F

[ ]  Transition Report on Form 11-K
[ ] Transition Report on Form 10-Q

[ ]  Transition Report on Form N-SAR

For the Transition Period Ended:

If the notification relates to a portion of the filing checked above,
identify the item(s) to which the notification relates:

PART I - REGISTRANT INFORMATION

PIC Mid Cap Portfolio
Full Name of Registrant

_________________
Former Name if Applicable

300 N. Lake Avenue
Address of Principal Executive Office (Street and Number)

Pasadena, CA 91101
City, State and Zip Code
PART 11 - RULES 12b-25(b) and (c)
If the subject report could not be filed without unreasonable effort
or expense and the registrant seeks relief pursuant to Rule
12b-25(b), the following should be completed.
(Check box if appropriate)

[x ]  (a) The reasons described in reasonable detail in Part III
of this form could not be eliminated without unreasonable
effort,or expense;

[ ]  (b) The subject annual report, semi-annual report, transition
report on Form 10-K, Form 20-F, 11-K, Form N-SAR,
or portion thereof, will be filed on or before the fifteenth
calendar day following the prescribed due date;
or the subject quarterly report of transition report on
Form IO-Q, or portion thereof will be filed on or before
the fifth calendar day following the prescribed
due date; and

[ ]  (c) The accountant's statement or other exhibit required
by rule 12b-25(c) has been attached if applicable.

<PAGE>
PART III - NARRATIVE

State below in reasonable detail the reasons why the
Form 10-K and Form 10-KSB, 11-K, 20-F, IO-Q
and Form IO-QSB, N-SAR, or other transition report
or portion thereof, could not be filed within the
prescribed period.

Waiting for financial information.



PART IV - OTHER INFORMATION

(1)   Name and telephone number of person to contact
in regard to this notification

Rita Dam                      626-852-1033
(Name)                      (Area Code)      (Telephone Number)

(2)  Have all other periodic reports required under  section 13 or
15(d) of the Securities Exchange Act of 1934 or Section 30
of  the Investment Company Act of 1940 during the preceding
12 months (or for such shorter period that the registrant was
required to file such reports), been filed. If answer is no,
identify report(s).


                                                     [x ] YES     [ ] NO
(3)  Is it anticipated that any significant change in results of
operations from the corresponding period for the last fiscal
year will be reflected by the earnings statement to be included
in the subject report or portion thereof?
                                                          [ ] YES      [x ] NO

If so, attach an explanation of the anticipated change, both
narratively, and, if appropriate, state the reasons why a
reasonable estimate of the results cannot be made.

PIC Mid Cap Portfolio
(Name of Registrant as Specified in Charter)

has caused this notification to be signed on its behalf by the
undersigned hereunto duly authorized.


Date:     December 30, 1999       By:   /s/ Rita Dam







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