EX-99.77B Accountant's Report on Internal Control
KPMG
4200 Norwest Center
90 South Seventh Street
Minneapolis, MN 55402
Independent Auditors' Report on Internal Accounting Control
The Board of Directors and Shareholders
Advantus Index 500 Fund, Inc.:
In planning and performing our audits of the financial statements of Advantus
Index 500 Fund, Inc. for the year ended July 31, 2000, we considered its
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, not to provide assurance on the internal control.
The management of Advantus Index 500 Fund, Inc. 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. Those controls
include the safeguarding of assets against unauthorized acquisition, use, or
disposition.
Because of inherent limitations in internal control, errors or irregularities
may occur and not be detected. Also, projection of any evaluation of internal
control to future periods is subject to the risk that it may become inadequate
because of changes in conditions or that the effectiveness of the design and
operation may deteriorate.
Our consideration of the internal control would not necessarily disclose all
matters in the 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 caused by errors 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 internal control and its operation,
including controls for safeguarding securities, that we consider to be a
material weakness as defined above.
This report is intended solely for the information and use of management, the
Board of Directors of Advantus Index 500 Fund, Inc., and the Securities and
Exchange Commission and is not intended to be and should not be used by anyone
other than these specified parties.
KPMG LLP
Minneapolis, Minnesota
September 8, 2000
