MANAGERS FUNDS
40-17F2, 2000-07-05
Previous: KEY TRONIC CORP, 4, 2000-07-05
Next: MATRIX ADVISORS VALUE FUND INC, 497, 2000-07-05







                REPORT OF INDEPENDENT ACCOUNTANTS


To the Trustees of The Managers Funds:
     Managers Emerging Markets Equity Fund:


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
Managers Emerging Markets 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 July
30, 1999, October 29, 1999 and December 31, 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 conducted 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 July 30, 1999
and October 29, 1999, without prior notice to management, and
December 31, 1999, and with respect to agreement of security
purchases and sales, for the period from December 31, 1998 (the
date of our last examination), through December 31, 1999:

-    Confirmation of securities held by institutions in book
     entry form (i.e., the Depository Trust Company), including
     reconciliation of such confirmations to the custodian's records;

-    Confirmation of securities held by unaffiliated
     international sub-custodians;

-    Reconciliation of such securities to the books and records
     of the Fund and the custodian;

-    Confirmation of a repurchase agreement with the bank and
     agreement of underlying collateral with custodian records; and

-    Agreement of fifteen security purchases and fifteen security
     sales or maturities since our last report from the books and
     records of the Fund 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.

<PAGE>

In our opinion, management's assertion 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 July 30,
1999, October 29, 1999 and December 31, 1999, with respect to
securities reflected in the investment account of the Fund is
fairly stated, in all material respects.

This report is intended solely for the information and use of the
Trustees, management, 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
February 22, 2000


<PAGE>

                       [THE MANAGERS FUNDS LOGO]

MANAGEMENT STATEMENT REGARDING COMPLIANCE WITH CERTAIN PROVISIONS
              OF THE INVESTMENT COMPANY ACT OF 1940



We, as members of management of Managers Emerging Markets 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 July 30, 1999,
October 29, 1999 and December 31, 1999, and from December 31,
1998 through December 31, 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 July 30,
1999, October 29, 1999 and December 31, 1999, and from December
31, 1998 through December 31, 1999, with respect to securities
reflected in the investment account of the Fund.


The Managers Funds
/s/Donald S. Rumery
Donald S. Rumery
Treasurer



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