AXP INTERNATIONAL FUND INC
NSAR-B, EX-99, 2000-12-22
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           Independent Auditors' Report on Internal Accounting Control

     The Board of Directors and Shareholders
     AXP International Fund, Inc.:


     In planning and  performing  our audits of the financial  statements of AXP
     International  Fund (a series within AXP International  Fund, Inc.) for the
     year ended October 31, 2000, and AXP European  Equity Fund (a series within
     AXP International  Fund, Inc.) for the period from June 26, 2000 to October
     31,  2000,  we  considered  their  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,  not to
     provide assurance on the internal control.

     The  management  of  AXP  International   Fund,  Inc.  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 entity's objective of
     preparing  financial  statements  for  external  purposes  that are  fairly
     presented in conformity  with  generally  accepted  accounting  principles.
     Those controls  include the  safeguarding  of assets  against  unauthorized
     acquisition, use, or disposition.

     Because  of   inherent   limitations   in  internal   control,   errors  or
     irregularities  may  occur and not be  detected.  Also,  projection  of any
     evaluation  of  internal  control to future  periods is subject to the risk
     that it may become inadequate  because of changes in conditions or that the
     effectiveness of the design and operation may deteriorate.

     Our  consideration of the internal  control would not necessarily  disclose
     all matters in the 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  caused by 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 matters involving the internal control and
     its operation,  including  controls for  safeguarding  securities,  that we
     consider to be a material weakness as defined above.

     This report is intended  solely for the  information and use of management,
     the Board of Directors of AXP International  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.

                                    KPMG LLP

      Minneapolis, Minnesota
      December 1, 2000



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