EII REALTY SECURITIES TRUST
NSAR-B, EX-99, 2000-08-23
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                        EXHIBIT INDEX

Exhibit A: Attachment to item 77B:
           Accountants report on internal control
-------------------------------------------------------

Exhibit A:
Report of Independent Auditors

To the Shareholders and Board of Directors of
E.I.I. Realty Securities Fund

In planning and performing our audit of the financial statements of
E.I.I. Realty Securities Fund for the year ended June 30, 2000, we
considered its internal control, including control activities for
safeguarding securities, 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 internal control.

The management of E.I.I. Realty Securities Fund 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 control.
Generally, internal 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 internal controls
include the safeguarding of assets against unauthorized
acquisition, use, or disposition.

Because of inherent limitations in internal control, misstatements
due to errors 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 internal control may become inadequate
because of changes in conditions, or that the degree of compliance
with the policies or procedures may deteriorate.

Our consideration of 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 specific
internal control components does not reduce to a relatively low
level the risk that 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 internal control, including control
activities for safeguarding securities, and its operation that we
consider to be material weaknesses as defined above at June 30,
2000.

This report is intended solely for the information and use of
management, the Board of Directors of E.I.I. Realty Securities
Fund, and the Securities and Exchange Commission and is not
intended to be and should not be used by anyone other than these
specified parties.

ERNST & YOUNG LLP

August 10, 2000




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