EX-99.77B Accountant's Report on Internal Control
Independent Auditors' Report on Internal Accounting Control
The Board of Directors and Shareholders
Advantus Money Market Fund, Inc.:
In planning and performing our audit of the financial statements
of Advantus Money Market 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 Money Market 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 Money Market 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
