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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION --------------------------
WASHINGTON, D.C. 20549 OMB APPROVAL
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FORM N-17f-2 OMB NUMBER: 3235-0360
EXPIRES:
Certificate of Accounting of Securities and Similar ESTIMATED AVERAGE BURDEN
Investments in the Custody of HOURS PER RESPONSE... 0.06
Management Investment Companies --------------------------
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
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1. Investment Company Act File Number: Date examination completed:
811-02913 September 30, 1999
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2. State identification Number:
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AL AK AZ AR CA CO
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CT DE DC FL GA HI
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ID IL IN IA KS KY
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LA ME MD MA MI MN
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MS MO MT NE NV NH
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NJ NM NY NC ND OH
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OK OR PA RI SC SD
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TN TX UT VT VA WA
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WV WI WY PUERTO RICO
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Other (specify):
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3. Exact name of investment company as specified in registration statement:
Dresdner RCM International Growth Equity Fund
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4. Address of principal executive office (number, street, city, state, zip code):
Four Embarcadero Center, San Francisco, CA 94111
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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
SEC 2198 (11-91)
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REPORT OF INDEPENDENT ACCOUNTANTS
To the Board of Directors of Dresdner RCM Capital Funds Incorporated:
We have examined management's assertion, included in the accompanying Management
Statement Regarding Compliance with Certain Provisions of the Investment Company
Act of 1940, about the Dresdner RCM International Growth Equity Fund's (the
"Fund") compliance with the requirements of subsections (b) and (c) of rule
17f-2 under the Investment Company Act of 1940 (the Act) as of
September 30, 1999. Management is responsible for the Fund's compliance with
those requirements. Our responsibility is to express an opinion on management's
assertion about the Fund's compliance based on our examination.
Our examination was made in accordance with attestation 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 September 30, 1999, and with respect to agreement of
security purchases and sales, for the period from January 29, 1999 (the date of
our last examination), through September 30, 1999:
- - Count and inspection of all securities located in the vault, if any, of
State Street Bank and Trust, in Quincy, Massachusetts, the Custodian;
- - Confirmation of all securities held by Dresdner Bank AG and the Depository
Trust Company in book entry form;
- - 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; and
- - Agreement of 9 security purchases and 7 security sales or maturities since
our last report from the books and records of the Company to broker
confirmations.
We believe that our examination provides a reasonable basis for our opinion. Our
examination does not provide a legal determination on the Fund's compliance with
specified requirements.
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In our opinion, management's assertion that the Dresdner RCM International
Growth Equity Fund, were in compliance with the requirements of subsections (b)
and (c) of rule 17f-2 of the Investment Company Act of 1940 as of
September 30, 1999, with respect to securities reflected in the investment
account of the Funds is fairly stated, in all material respects.
This report is intended solely for the information and use of the Board of
Directors of the Dresdner RCM Capital Funds, Inc., the management of the
Dresdner RCM International Growth Equity 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.
PricewaterhouseCoopers LLP
Boston, Massachusetts
November 29, 1999
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November 29, 1999
PricewaterhouseCoopers LLP
160 Federal Street
Boston, Massachusetts 02110
RE: MANAGEMENT STATEMENT REGARDING COMPLIANCE WITH CERTAIN PROVISIONS OF THE
INVESTMENT COMPANY ACT OF 1940
We, as members of management of the Dresdner RCM International Growth Equity
Fund (the "Fund"), 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
Fund's compliance with the requirements of subsections (b) and (c) of rule 17f-2
as of September 30, 1999, and from January 29, 1999 through September 30, 1999.
Based on this evaluation, we assert that the Fund was in compliance with the
requirements of subsections (b) and (c) of rule 17f-2 of the Investment Company
Act of 1940 as of September 30, 1999, and from January 29, 1999, through
September 30, 1999, with respect to securities reflected in the investment
account of the Fund.
Dresdner RCM Capital Funds, Inc.
/s/ Steven Wong
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Steven Wong, Assistant Treasurer
