MAXIM SERIES FUND INC
NSAR-A, EX-99.77B, 2000-12-19
DRILLING OIL & GAS WELLS
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Deloitte & Touche LLP
Suite 3600
555 Seventeenth Street
Denver, Colorado 80202-3942

Tel: (303) 292-5400
Fax: (303) 312-4000
www.us.deloitte.com
                                                                        Deloitte
                                                                        & Touche

INDEPENDENT AUDITORS REPORT

To the Board of Directors and Shareholder of
Maxim Series Fund, Inc.:

In planning and performing our audit of the financial  statements of Maxim Vista
Growth & Income  Portfolio of Maxim Series  Fund,  Inc.  (the Fund) for the year
ended  October 31, 2000 ( on which we have issued our report  dated  December 1,
2000),  we considered its internal  control,  including  control  activities for
safeguarding  securities,  in order 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 the Funds
internal control.

The  management of the 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
controls.  Generally,  controls  that are  relevant  to an audit  pertain to the
entitys objective of preparing financial  statements for external purposes that
are fairly presented in conformity with generally accepted accounting principles
generally  accepted in the United States of America.  Those controls include the
safeguarding of assets against unauthorized acquisition, use, or disposition.

Because of inherent limitations in internal control,  misstatements due to error
or fraud may occur and not be detected.  Also,  projection of any  evaluation of
internal  control to future  periods  is  subject to the risk that the  internal
control  may become  inadequate  because of  changes in  conditions  or that the
degree of compliance with policies and 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 internal control components does not reduce to a relatively low level the
risk that  misstatements due to error 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 matter  involving  the Funds
internal  control  and  its  operation,   including  controls  for  safeguarding
securities,  that we consider to be material  weaknesses  as defined above as of
October 31, 2000.

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

/s/ Deloitte & Touche LLP

December 1, 2000



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