[KPMG LOGO OMITTED]
99 High Street Telephone 617-988-1000
Boston, MA 02110-2371 Fax 617-988-0800
INDEPENDENT ACCOUNTANTS' REPORT
The Board of Directors of
GE~Investments Funds, Inc.
We have examined management's assertion that the S&P 500 Index Fund (the
"Fund"), one of the portfolios 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 August 31, 1999, including 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 August 31, 1999 and for the period from May 31, 1999 through
August 31, 1999, with respect to securities transactions, 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 included in 1) or 2) above;
4) Reconciliation between the Fund's accounting records and the custody
records as of August 31, 1999 and verified reconciling items;
5) Agreement of pending trade activity for the Fund as of August 31, 1999 to
the corresponding subsequent cash statements;
6) Agreement to the books and records of the Fund of a sample of purchases and
sales of securities for the period May 31, 1999 (the date of our last
examination) through August 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 August 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, 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.
[SIGNATURE]
KPMG LLP
December 10, 1999
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[GE LOGO]
GE INVESTMENTS
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GE INVESTMENTS
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 August 31, 1999, and from May 31,
1999 to August 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 August 31, 1999, and from May 31, 1999 through August 31,
1999, with respect to securities reflected in the investment account of the
Fund.
GEI Investments Funds, Inc. (S&P 500 Index Fund),
By:
[SIGNATURE]
Michael J. Cosgrove
President
[SIGNATURE]
Michael Tansley
Treasurer
