KPMG [LOGO OMITTED]
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99 High Street Telephone 617 988 1000
Boston, MA 02110-2371 Fax 617 988 0800
INDEPENDENT ACCOUNTANTS' REPORT
To Board of Directors of
GE Investments Funds, Inc.
We have examined management's assertion about the S&P 500 Index Fund (the
"Fund"), one of the portfolios of the GE Investments Funds, Inc., compliance
with the requirements of subsection (b) and (c) of Rule 17f-2 under the
Investment Company Act of 1940 as of May 31, 1999, included in the Management
Assertion Regarding Compliance with Certain Provisions of the Investment
Company Act of 1940. 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 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 May 31, 1999 and for the period from December 31, 1999 through
May 31, 1999, with respect to securities transactions:
1) Confirmation of all securities held in book entry from by the
Depository Trust Company and examination of selected security
position reconciliations;
2) Confirmation of all securities hypothecated, pledged or placed in
escrow with brokers;
3) Inspection of documentation of other securities held in safekeeping
by State Street Bank & Trust (the "Custodian") but not included in 1)
or 2) above;
4) Reconciliation between the Fund's accounting records and the custody
records as of May 31, 1999 and verified reconciling items;
5) We agreed pending trade activity for the Fund as of May 31, 1999 to
their corresponding subsequent cash statements;
6) We agreed to the books and records of the Fund a sample of purchases
and sales of securities for the period December 31, 1998 (the date
of our last examination) through May 31, 1999, noting that they
had been properly recorded.
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
the specified requirements.
In our opinion, management's assertion that the S&P 500 Index Fund, a portfolio
of the GE Investments Funds, Inc., was in compliance with the requirements of
subsections (b) and (c) of Rule 17f-2 of the Investment Company Act of 1940
as of May 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 management of the
GE Investment Funds, Inc., and the Securities and Exchange Commission and
should not be used for any other purpose.
/S/ SIGNATURE
KPMG LLP
June 28, 1999
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[GE LOGO OMITTED]
GE INVESTMENTS
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GENERAL ELECTRIC INVESTMENT CORPORATION
3003 SUMMER STREET, P.O. BOX 7900
STAMFORD, CT 06904-7900
203-326-2300
MANAGEMENT ASSERTION REGARDING COMPLIANCE WITH
CERTAIN PROVISIONS OF THE INVESTMENT COMPANY ACT OF 1940
We, as members of management of one of the portfolios of GE Investment Funds,
Inc., the S&P 500 Index 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 an
effective internal control structure over compliance with Rule 17f-2
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 May 31, 1999, and
from December 31, 1998 to May 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 May 31, 1999, and from December 31, 1998 through May 31, 1999,
with respect to securities reflected in the investment account of the Fund.
GEI Investments Funds (S&P 500 Index Fund),
By:
/S/SIGNATURE
Michael J. Cosgrove
President
/S/ SIGNATURE
Michael J. Tansley
Treasurer
