U.S. Securities and Exchange Commission
Washington, D.C. 20549
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:
811-2546
February 26, 1999
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:
Fidelity Commonwealth Trust: Spartan Market Index Fund.
4. Address of principal executive office: (number, street, city, state,
zip code)
82 Devonshire Street, Boston, MA 02109
INSTRUCTIONS
This Form must be completed by the 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
Report of Independent Accountants
To the Board of Trustees of:
Fidelity Concord Street Trust: Spartan U.S. Equity Index Fund
Fidelity Concord Street Trust: Spartan Total Market Index Fund
Fidelity Concord Street Trust: Spartan Extended Market Index Fund
Fidelity Commonwealth Trust: Spartan Market Index Fund
Variable Insurance Products Fund II: Index 500 Portfolio
We have examined management's assertion about Fidelity Concord Street Trust:
Spartan U.S. Equity Index Fund, Fidelity Concord Street Trust: Spartan Total
Market Index Fund,
Fidelity Concord Street Trust: Spartan Extended Market Index Fund, Fidelity
Commonwealth Trust: Spartan Market Index Fund and Variable Insurance Products
Fund II: Index 500 Portfolio (collectively the "Funds") compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 under the Investment
Company Act of 1940 ("the Act") as of February 26, 1999 included in its
representation letter dated August 23, 1999. 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 Fund's 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 February 26, 1999 and with respect to agreement of security
purchases and sales, for the period from October 30, 1998 (the date of our
last examination) through February 26, 1999:
* Count and inspection of all securities located in the vault of Bankers
Trust in New York;
* Confirmation of all securities held by institutions in book entry form-
The Federal Reserve Bank of New York, The Depository Trust Company, CREST
and CHESS;
* Confirmed all securities record-kept at banks with whom the Custodian
and the Funds have contracted to provide sub-custodian services without
prior notice to management including Citicorp-Florida, Generale Bank
Belgium, Creditanstalt Bankyerein Austria, Barclays Bank London, Royal
Bank of Canada, Den Danske Bank Denmark, Merita Bank Finland, Banque
Paribas France, Dresdner Bank Germany, National Bank of Greece, Deutsche
Bank India, Standard Charter Bank Indonesia, Allied Irish Bank Ireland,
Standard Charter Bank Hong Kong, Citibank Italy, Sumitomo Bank Tokyo,
Standard Charter Bank Korea, Custodian & Nominees Malaysia, Bancomer
Mexico, ABN AMRO Netherlands, ANZ Nominees Limited, New Zealand,
Euroclear Belgium, Standard Charter Bank Pakistan, Standard Charter
Bank Manila, Banco Espirito Portugal, United Overseas Bank Singapore,
Banco Santander Spain, Svenska Handelsbanken Sweden, Swiss Bank Corp
Switzerland, Barclays Bank Bostwana, Standard Charter Bank Thailand,
ABAS Securities, CEDEL, Citibank Poland, and Citibank Norway;
* Confirmation of all securities hypothecated, pledged, placed in escrow,
or out for transfer with brokers, pledgees and/or transfer agents;
* Reconciliation of all such securities to the books and records of the
Funds and the Custodian;
* Confirmation of all repurchase agreements with brokers/banks and
agreement of underlying collateral with Bankers Trust records; and
* Agreed selected securities purchased and securities sold or matured
since our last report from the books and records of the Funds to broker
confirms.
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 specified requirements.
In our opinion, management's assertion 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 February 26, 1999 with respect to
securities reflected in the investment accounts of the Funds are fairly
stated, in all material respects.
This report is intended solely for the information and use of management
of the Funds and the Securities and Exchange Commission and should not
be used for any other purpose.
PricewaterhouseCoopers LLP
New York, New York
August 23, 1999
