KPMG [LOGO OMITTED]
757 Third Avenue Telephone 212 758 9700
New York, NY 10017 Fax 212 872 3001
INDEPENDENT ACCOUNTANTS' REPORT
To the Board of Directors of
GE Investments Funds, Inc.
We have examined management's assertion that the S&P 500 Index Fund (the
"Fund"), a series of the GE Investments Funds, Inc., complied with the
requirements of subsection (b) and (c) of Rule 17f-2 under the Investment
Company Act of 1940 as of March 31, 2000, 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 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 March 31, 2000 and with respect to agreement of security
purchases and sales, for the period from December 31, 1999 through March 31,
2000 without prior notice to management.
1) Confirmation of securities held in book entry form 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 March 31, 2000 and verified reconciling items;
5) Agreement of pending trade activity for the Fund as of March 31, 2000 to
their corresponding subsequent cash statements;
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6) Agreement of a sample of purchases and sales of securities for the period
December 31, 1999 (the date of our last examination) through March 31,
2000, to the books and records of the Fund 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 series of
GE Investments Funds, Inc., complied with the requirements of subsections (b)
and (c) of Rule 17f-2 of the Investment Company Act of 1940 as of March 31,
2000, 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 and the
Board of Directors of the GE Investment Funds, 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/ SIGNATURE
KPMG LLP
April 21, 2000
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[GE LOGO OMITTED]
GE ASSET MANAGEMENT
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GE ASSET MANAGEMENT INCORPORATED
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 Investments 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 March 31, 2000, and
from December 31, 1999 to March 31, 2000.
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 March 31, 2000, and from December 31, 1999 through March
31, 2000, with respect to securities reflected in the investment account of the
Fund.
GE Investments Funds, Inc. (S&P 500 Index Fund),
By:
/S/SIGNATURE
Michael J. Cosgrove
President
/S/ SIGNATURE
Michael J. Tansley
Treasurer
