SUB-ITEM 77(K)
Change in Certifying Accountant
KPMG LLP was previously the independent public accountant for the Short-Term
Investments Trust Government & Agency Portfolio ("Government & Agency
Portfolio"). Due to an inadvertent investment in the Government & Agency
Portfolio and a change in SEC rules regarding auditor independence, KPMG LLP
resigned as of December 28, 2000. The Board of Trustees of the Trust, upon
recommendation of its Audit Committee, accepted the resignation of KPMG LLP and
appointed Tait, Weller & Baker as independent public accountants for the
Government & Agency Portfolio. KPMG LLP had served as independent public
accountants for the year ended August 31, 1999. The audit report of KPMG LLP on
the financial statements of the Government & Agency Portfolio for the year
ended August 31, 1999 did not contain any adverse opinion or disclaimer of
opinion, nor were they qualified or modified as to uncertainty, audit scope, or
accounting principles. In connection with the audit for the year ended August
31, 1999, and the subsequent period through December 28, 2000, there were no
disagreements with KPMG LLP on any matter of accounting principles or
practices, financial statement disclosure, or auditing scope or procedures,
which disagreements if not resolved to their satisfaction would have caused
them to make reference in connection with their opinion to the subject matter
of the disagreement.
Neither the Government & Agency Portfolio nor anyone on its behalf consulted
with Tait, Weller & Baker at any time prior to their engagement with respect to
the application of accounting principles to a specified transaction, either
completed or proposed or the type of audit opinion that might be rendered on
the Government & Agency Portfolio's financial statements.
<PAGE>
SUB-ITEM 77(K)
Change in Certifying Accountant
KPMG LLP was previously the independent public accountant for the Short-Term
Investments Trust Treasury Portfolio ("Treasury Portfolio"). Due to an
inadvertent investment in the Treasury Portfolio and a change in SEC rules
regarding auditor independence, KPMG LLP resigned as of December 28, 2000. The
Board of Trustees of the Trust, upon recommendation of its Audit Committee,
accepted the resignation of KPMG LLP and appointed Tait, Weller & Baker as
independent public accountants for the Treasury Portfolio. KPMG LLP had served
as independent public accountants for the year ended August 31, 1999. The audit
report of KPMG LLP on the financial statements of the Treasury Portfolio for
the year ended August 31, 1999 did not contain any adverse opinion or
disclaimer of opinion, nor were they qualified or modified as to uncertainty,
audit scope, or accounting principles. In connection with the audit for the
year ended August 31, 1999, and the subsequent period through December 28,
2000, there were no disagreements with KPMG LLP on any matter of accounting
principles or practices, financial statement disclosure, or auditing scope or
procedures, which disagreements if not resolved to their satisfaction would
have caused them to make reference in connection with their opinion to the
subject matter of the disagreement.
Neither the Treasury Portfolio nor anyone on its behalf consulted with Tait,
Weller & Baker at any time prior to their engagement with respect to the
application of accounting principles to a specified transaction, either
completed or proposed or the type of audit opinion that might be rendered on
the Treasury Portfolio's financial statements.
<PAGE>
SUB-ITEM 77(K)
Change in Certifying Accountant
KPMG LLP was previously the independent public accountant for the Short-Term
Investments Trust Government TaxAdvantage Portfolio ("Government TaxAdvantage
Portfolio"). Due to an inadvertent investment in the Government TaxAdvantage
Portfolio and a change in SEC rules regarding auditor independence, KPMG LLP
resigned as of December 28, 2000. The Board of Trustees of the Trust, upon
recommendation of its Audit Committee, accepted the resignation of KPMG LLP and
appointed Tait, Weller & Baker as independent public accountants for the
Government TaxAdvantage Portfolio. KPMG LLP had served as independent public
accountants for the year ended August 31, 1999. The audit report of KPMG LLP on
the financial statements of the Government TaxAdvantage Portfolio for the year
ended August 31, 1999 did not contain any adverse opinion or disclaimer of
opinion, nor were they qualified or modified as to uncertainty, audit scope, or
accounting principles. In connection with the audit for the year ended August
31, 1999, and the subsequent period through December 28, 2000, there were no
disagreements with KPMG LLP on any matter of accounting principles or
practices, financial statement disclosure, or auditing scope or procedures,
which disagreements if not resolved to their satisfaction would have caused
them to make reference in connection with their opinion to the subject matter
of the disagreement.
Neither the Government TaxAdvantage Portfolio nor anyone on its behalf
consulted with Tait, Weller & Baker at any time prior to their engagement with
respect to the application of accounting principles to a specified transaction,
either completed or proposed or the type of audit opinion that might be
rendered on the Government TaxAdvantage Portfolio's financial statements.
<PAGE>
SUB-ITEM 77(K)
[KPMG Logo]
700 Lousiana Telephone 713 319 2000
Houston, TX 77002 Fax 713 319 2041
January 2, 2001
Securities and Exchange Commission
Washington, D.C. 20549
We were previously accountants for Short-term Investments Trust and, under the
date of August 31, 1999, we reported on the financial statements of the
portfolios of Short-term Investments Trust as of and for the year ended August
31, 1999. On December 28, 2000 we resigned. We have read Short-term Investments
Trust's statements included under Sub-Item 77K in its Amended Form N-SAR and we
agree with such statements.
Very truly yours,
/s/ KPMG LLP
