EX-99.77B Accountant's Report on Internal Control
Independent Auditors' Report on Internal Accounting Control
The Board of Directors and Shareholders
Advantus Mortgage Securities Fund, Inc.:
In planning and performing our audit of the financial statements
of Advantus Mortgage Securities Fund, Inc. for the year ended
September 30, 2000, we considered its 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 Advantus Mortgage Securities 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 errors 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 material
weaknesses as defined above.
This report is intended solely for the information and use of
management, the Board of Directors of Advantus Mortgage
Securities 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
November 10, 2000
