SYMPHONY ASSET MANAGEMENT INC
13F-NT, 1999-11-15
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                                  UNITED STATES
                       SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                    FORM 13F

                               FORM 13F COVER PAGE

Report for the Calendar Year or Quarter Ended: September 30, 1999

Check here if Amendment [  ]; Amendment Number:
This Amendment (Check only one.): [  ] is a restatement.
                                  [  ] adds new holdings entries.

Institutional Investment Manager Filing this Report:

Name:    Symphony Asset Management, Inc.
Address: 555 California Street, Suite 2975
         San Francisco, CA 94104


13F File Number:  28-5764

The institutional  investment  manager filing this report and the person by whom
it is signed hereby  represent  that the person signing the report is authorized
to  submit  it,  that all  information  contained  herein is true,  correct  and
complete,  and  that it is  understood  that  all  required  items,  statements,
schedules, lists, and tables, are considered integral parts of this form.


Person Signing this Report on Behalf of Reporting Manager:

Name:     Neil L. Rudolph
Title:    Chief Operating Officer
Phone:    415/676-4000

Signature, Place, and Date of Signing:

      /s/ Neil L. Rudolph         San Francisco, CA            11/10/99
   -------------------------- -------------------------- -----------------------
           [Signature]              [City, State]               [Date]

Report Type (Check only one.):

[ ]  13F HOLDINGS REPORT.  (Check here if all holdings of this reporting manager
     are reported in this report)

[X]  13F NOTICE. (Check here if no holdings reported are in this report, and all
     holdings are reported by other reporting manager(s))

[ ]  13F  COMBINATION  REPORT.  (Check here if a portion of the holding for this
     reporting manager are reported by other reporting manager(s))


List of other Included Managers:

Provide  a  number  list of the  name(s)  and Form  13F  file  number(s)  of all
instutional  investment  managers  with  respect to which this report is filled,
other than the manager filing this report.

No.          Form 13F File Number     Name
- ---          --------------------     ----
1            28-3128                  Charles Schwab Investment Management, Inc.




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