WELLS FARGO VARIABLE TRUST
40-17F2, 2000-09-07
Previous: WELLS FARGO FUNDS TRUST, 40-17F2, 2000-09-07
Next: CAVION TECHNOLOGIES INC, PRES14A, 2000-09-07



<PAGE>

                             [LETTERHEAD OF KPMG]


                         Independent Auditors' Report


To the Board of Trustees of
Wells Fargo Variable Trust:

We have examined management's assertion, included in the accompanying Management
Statement Regarding Compliance with Certain Provisions of the Investment Company
Act of 1940, that the funds listed in Appendix A, portfolios of Wells Fargo
Variable Trust (the "Funds"), complied with the requirements of subsections (b)
and (c) of Rule 17f-2 under the Investment Company Act of 1940 as of June 30,
2000. Management is responsible for the Funds' compliance with those
requirements. Our responsibility is to express an opinion on management's
assertion about the Funds' compliance based on our examination.

Our examination was made in accordance with standards established by the
American Institute of Certified Public Accountants and, accordingly, included
examining, on a test basis, evidence about the Funds' compliance with those
requirements and performing such other procedures as we considered necessary in
the circumstances. Included among our procedures were the following tests
performed as of June 30, 2000, and with respect to agreement of security
purchases and sales for the period from the date of our last examination (as
listed in Appendix A) through June 30, 2000.

(1)  Inspection of documentation of all securities located in the vault, if any,
     of Norwest Bank Minnesota, N.A., the Custodian;

(2)  Inspection of documentation of securities held in book entry form by
     Bankers Trust Company, Depository Trust Company, and the Federal Reserve
     Bank and examination of selected security position reconciliations;

(3)  Inspection of documentation of other securities held in safekeeping by the
     Custodian but not included in (1) or (2) above and examination of selected
     security position reconciliations.
<PAGE>

[LOGO]

Wells Fargo Variable Trust
Page 2
August 14, 2000


(4)  Confirmation or inspection of documentation of all securities purchased but
     not received, hypothecated, pledged, placed in escrow, or out for transfer
     with brokers, pledges and/or transfer agents;

(5)  Reconciliation of all such securities to the books and records of the Funds
     and the Custodian; and

(6)  Tests of selected security transactions since the date of our last report.

We believe that our examination provides a reasonable basis for our opinion.
Our examination does not provide a legal determination on the Funds' compliance
with the specified requirements.

In our opinion, management's assertion that Wells Fargo Variable Trust complied
with the requirements of subsections (b) and (c) of Rule 17f-2 of the Investment
Company Act of 1940 as of June 30, 2000, with respect to securities reflected in
the investment accounts of Wells Fargo Variable Trust, is fairly stated, in all
material respects.

This report is intended solely for the information and use of management and the
Board of Trustees of Wells Fargo Variable Trust 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


San Francisco, California
August 14, 2000
<PAGE>

                                                     [LOGO OF WELLS FARGO FUNDS]

August 14, 2000

KPMG LLP
Three Embarcadero
San Francisco, CA 94110-4073

RE:  Management Statement Regarding Compliance with Certain Provisions of the
     Investment Company Act of 1940

Ladies and Gentlemen:

We, as members of management of the funds listed in Appendix A, portfolios of
Wells Fargo Variable Trust (the "Funds"), are responsible for complying with the
requirements of subsections (b) and (c) of Rule 17f-2, "Custody of Investments
by Registered Management Investment Companies," of the Investment Company Act of
1940. We are also responsible for establishing and maintaining effective
internal controls over compliance with those requirements. We have performed an
evaluation of the Funds' compliance with the requirements of subsections (b) and
(c) of Rule 17f-2 as of June 30, 2000, and for the period from the date of your
last examination (as listed in Appendix A) through June 30, 2000.

Based on this evaluation, we assert that the Funds were in compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 of the Investment Company
Act of 1940 as of June 30, 2000 and for the period from the date of your last
examination (as listed in Appendix A) through June 30, 2000 with respect to
securities reflected in the investment accounts of the Funds.


Sincerely,

/s/ Karla M Rabusch

Karla Rabusch
Senior Vice President and
Chief Financial Officer
Wells Fargo Mutual Funds Group
<PAGE>




                                                  ------------------------------
                                                  / OMB Number:       3235-0360/
                                                  / Expires:      July 31, 1991/
                                                  / Estimated average burden   /
                                                  / hours per response.... 0.05/
                                                  ------------------------------

                                 FORM N-17f-2

              Certificate of Accounting of Securities and Similar
                         Investments in the Custody of
                        Management Investment Companies

                   Pursuant to Rule 17f-2 [17 CFR 270.17f-2]

--------------------------------------------------------------------------------
1. Investment Company Act File Number:              Date examination completed:

801 8202                                            6/30/00
-------------------------------------------------------------------------------
2.  State Identification Number:

      -------------------------------------------------------------------------
       AL           AK          AZ           AR             CA           CO
      -------------------------------------------------------------------------
       CT           DE          DC           FL             GA           HI
      -------------------------------------------------------------------------
       ID           IL          IN           IA             KS           KY
      -------------------------------------------------------------------------
       LA           ME          MD           MA             MI           MN
      -------------------------------------------------------------------------
       MS           MO          MT           NE             NV           NH
      -------------------------------------------------------------------------
       NJ           NM          NY           NC             ND           OH
      -------------------------------------------------------------------------
       OK           OR          PA           RI             SC           SD
      -------------------------------------------------------------------------
       TN           TX          UT           VT             VA           WA
      -------------------------------------------------------------------------
       WV           WI          WY           PUERTO RICO
      -------------------------------------------------------------------------
       Other (specify):
-------------------------------------------------------------------------------
3. Exact name of investment company as specified in registration statement:

   WELLS FARGO
-------------------------------------------------------------------------------
4. Name under which business is conducted, if different from above:

-------------------------------------------------------------------------------
5. Address of principal place of business (number, street, city, state, zip
   code):
-------------------------------------------------------------------------------

INSTRUCTIONS

This Form must be completed by investment companies that have custody of
securities or similar investments.

Investment Company

1. All items must be completed by the investment company.

2. Give this Form to the independent public accountant who, in compliance with
Rule 17f-2 under the Act and applicable state law, examines securities and
similar investments in the custody of the investment company.

Accountant

3. Submit this Form to the securities and Exchange Commission and appropriate
   state securities administrators when filing the certificate of accounting
   required by Rule 17f-2 under the Act and applicable state law. File the
   original and one copy with the Securities and Exchange Commission's principal
   office in Washington, D.C., one copy with the regional office for the region
   in which the investment company's principal business operations are
   conducted, and one copy with the appropriate state administrator(s), if
   applicable.

         THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT

Note: The estimated average burden hours are made solely for purposes of the
      Paperwork Reduction Act, and are not derived from a comprehensive or even
      a representative survey or study of the costs of SEC rules and forms.
      Direct any comments concerning the accuracy of the estimated average
      burden hours for compliance with SEC rules and forms to Kenneth A. Fogash,
      Deputy Executive Director, U.S. Securities and Exchange Commission, 450
      Fifth Street, N.W., Washington, D.C. 20549 and Gary Waxman, Clearance
      Officer, Office of Management and Budget, Room 3208 New Executive Office
      Building, Washington, D.C. 20503.
<PAGE>

                                  Appendix A


                          Wells Fargo Variable Trust

                                                          Date of Last
                        Fund Name                         Examination
-------------------------------------------------------------------------

Corporate Bond Fund                                        March 31, 2000
Equity Income                                              March 31, 2000
Equity Value Fund                                          March 31, 2000
Growth Fund                                                March 31, 2000
Large Company Growth Fund                                  March 31, 2000
Money Market Fund                                          March 31, 2000
Small Cap Growth Fund                                      March 31, 2000


© 2022 IncJournal is not affiliated with or endorsed by the U.S. Securities and Exchange Commission