[Adopted in Release No. IC-17085 (P 84.434), effective September
25, 1989, 54 F.R. 32048]
U.S. Securities and Exchange Commission
Washington DC 20549
FORM N-17F-2
Form N-17f-2
Certificate of Accounting of Securities and Similar Investments
in the Custody of Management Investment Companies.
Pursuant to Rule 17f-2 [17CFR 270.17f-2]
1. Investment Company Act File Number:
Date Examination Complete:
11/30/98
SEI Index Funds - S& P 500 Index Portfolio
2. State Identification Number
See attached Exhibit A listing the fund availability by state
(If applicable the associated state permit number is provided).
2. Exact number of investment company as specified in registration
statement: 2-97111
3. Address of principal executive office: (number, street, city,
state, zip code)
One Freedom Valley
Wayne, PA 19087
INSTRUCTIONS
This form must be completed by the investment companies that have
custody of securities or similar investments.
Investment Company
1. All items must be completed by the investment company
2. Give this form to the independent public accountant who, in
compliance with Rule 17f-2 under the Act and applicable state law,
examines securities and similar investments in the custody of the
investment company.
Accountant
4. Submit this Form to the Securities and Exchange Commission and
appropriate state securities administrators when filing the
certificate of accounting required by Rule 17f-2 under the Act
and applicable state law. File the original and one copy with
the Securities and Exchange Commission's principal office in Washington
DC, one copy with the region in which the investment company's
principal business operations are conducted, and one copy with
the appropriate state administrator(s), if applicable.
THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT
Note: The estimated average burden hours are made solely for
purposes of the Paperwork Reduction Act, and are not derived
from a comprehensive or even a representative survey or study
of the costs of SEC rules and forms. Direct any comments concerning
the accuracy of the estimated average burden hours for compliance
with SEC rules and forms to Kenneth A. Fogash, Deputy Executive
Director, US Securities and Exchange Commission, 450 Fifth Street
NW Washington DC 20549 and Gary Waxman, Clearance Officer, Office
of Management and Budget, Room 3208 New Executive Office Building,
Washington DC 20503.
Exhibit A - State Permit Report
Fund Name State Filing Type File Number
SEI Index Funds
CALIFORNIA A=Annual 504-5132
COLORADO A=Annual IC 9101316
GEORGIA O=Other 56-851073
ILLINOIS A=Annual 9839784
INDIANA A=Annual 85-0281-IC
MINNESOTA G=Good Until S R-25346
NORTH CAROLINA A=Annual 1474
PENNSYLVANIA A=Annual 87-08-182MF
VIRGINIA A=Annual 1334
WEST VIRGINIA G=Good Until S BC-30495
WYOMING O=Other 18846
SEI Index Funds (Minnesota Exemption)
MINNESOTA A=Annual
SEI Index Funds
KENTUCKY A=Annual M24084
LOUISIANA A=Annual 56374
OHIO O=Other 14573
OKLAHOMA A=Annual 1-100797
OREGON A=Annual 94-1169
UTAH A=Annual 1864-06
SEI Index Funds - S&P 500 Index Portfolio
ALASKA O=Other 98 01394
ALABAMA A=Annual
ARKANSAS A=Annual 85-M0411-02
CONNECTICUT A=Annual S123473
DELAWARE A=Annual
HAWAII A=Annual
IDAHO A=Annual 30260
KANSAS A=Annual 94S0001644
MISSOURI A=Annual 205403
NEVADA A=Annual
NEW YORK O=Other 5-26-41-39
RHODE ISLAND A=Annual
SOUTH CAROLINA A=Annual MF5232
SEI Index Funds - S&P 500 Index Portfolio - Class A
ARIZONA A=Annual S-AB19522-QUAL
IOWA A=Annual 1-26153
MASSACHUSETTS A=Annual 96-4288-MR
MARYLAND A=Annual SM912351
MAINE A=Annual MF-R-98-11173
MICHIGAN A=Annual 227712
MISSISSIPPI A=Annual MF-96-07-103
MONTANA A=Annual 31234
NORTH DAKOTA G=Good Until S 6959
NEBRASKA A=Annual 027997
NEW HAMPSHIRE A=Annual
NEW MEXICO A=Annual 987206
SOUTH DAKOTA A=Annual 1628
TENNESSEE A=Annual RM98-3057
TEXAS G=Good Until S C-25098
VERMONT A=Annual 4/24/85-01
WASHINGTON G=Good Until S C-22261
WISCONSIN A=Annual 207824-03
SEI Index Funds - S&P 500 Index Portfolio - Class E
ARIZONA A=Annual S-0048615-QUAL
IOWA A=Annual 1-35993
KENTUCKY A=Annual M32407
LOUISIANA A=Annual 54113
MASSACHUSETTS A=Annual 96-2190-M
MARYLAND A=Annual SM960358
MAINE A=Annual MF-R-98-7841
MICHIGAN A=Annual 222820
MISSISSIPPI G=Good Until S MF-96-02-154
MONTANA A=Annual 34557
NORTH DAKOTA A=Annual N997
NEBRASKA A=Annual 023804
NEW HAMPSHIRE A=Annual
NEW MEXICO A=Annual 981612
OHIO O=Other 14574
OKLAHOMA A=Annual 1-127797
OREGON A=Annual 96-0189
SOUTH DAKOTA A=Annual 14317
TENNESSEE A=Annual RM98-3057
TEXAS G=Good Until S C-49692
UTAH A=Annual 5-3825-45
VERMONT A=Annual 2/28/96-18
WASHINGTON G=Good Until S C-52970
WISCONSIN A=Annual 312654-03
WEST VIRGINIA G=Good Until S BC-30495
MANAGEMENT STATEMENT REGARDING COMPLIANCE WITH CERTAIN
PROVISIONS OF THE INVESTMENT COMPANY ACT OF 1940
We, as members of management of the S&P 500 Index Portfolio of
SEI Index Funds' (the "Trust"), 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 effective internal controls over
compliance with those requirements. We have performed an evaluation
of the Trust's compliance with the requirements of subsections (b)
and (c) of Rule 17f-2 as of November 30, 1998, and from October 30,
1998 (last examination date) through November 30, 1998.
Based on this evaluation, we assert that the Trust was in compliance
with the requirements of subsections (b) and (c) of Rule 17f-2 of the
Investment Company Act of 1940 as of November 30, 1998, and from October
30, 1998 (last examination date) through November 30, 1998 with respect
to securities reflected in the investment account of the Trust.
Comerica Bank
By:
Stephen Graef
Stephen Graef
Vice President
Trust Operations
REPORT OF INDEPENDENT PUBLIC ACCOUNTANTS
To the Board of Trustees of
SEI Index Funds and the
Securities and Exchange Commission:
We have examined management's assertion about the S&P 500 Index
Portfolio of SEI Index Funds (the "Trust") compliance with the
requirements of subsections (b) and (c) of rule 17f-2 under the
Investment Company Act of 1940 (the "Act") as of November 30, 1998,
included in the accompanying Management Statement Regarding
Compliance with Certain Provisions of the Investment Company
Act of 1940. Management is responsible for the Trust's compliance
with those requirements. Our responsibility is to express an
opinion on management's assertion about the Trust'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 Trust'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 November 30, 1998, and with respect to agreement of security
purchases and sales, for the period from October 30, 1998
(the date of our last examination), through November 30, 1998:
We agreed a sample of securities shown on the books and records of
the SEI Index Funds as of November 30, 1998 to the safekeeping
reports of Comerica Bank, the custodian, noting agreement of
quantity and description, except for securities purchased/sold
but not received/delivered, pledged, or out for transfer on that
date, as to which we obtained documentation from the brokers.
For all securities shown on the safekeeping reports of Comerica
Bank as of November 30, 1998 which were designated as being held
by institutions in book entry form (which include but are not
limited to securities owned by SEI Index Funds), we confirmed
all such securities with those institutions which use the book
entry method of accounting for securities (Bankers Trust, Federal
Reserve Bank and The Depository Trust Company, the subcustodians).
For a sample of securities on the safekeeping reports of Comerica
Bank, we noted that the quantities and descriptions of such
securities listed on the safekeeping reports agreed with the
confirmations or that discrepancies were resolved. We tested,
on a sample basis, the resolution of such reconciling items
between the custodian and subcustodians.
We confirmed all repurchase agreements shown on the books and
records of SEI Index Funds as of November 30, 1998 with brokers,
noting agreement of quantity and description. We also agreed the
underlying collateral for such repurchase agreements, as confirmed
by such brokers, with the Comerica Bank safekeeping reports,
noting that such collateral was held for the account of SEI
Index Funds.
We agreed a sample of security purchases and security sales since
our last report from the books and records of the Trust to broker
confirmations.
We believe that our examination provides a reasonable basis for
our opinion. Our examination does not provide a legal
determination on the Trust's compliance with specified requirements.
In our opinion, management's assertion that the S&P 500
Index Portfolio of SEI Index Funds was in compliance with the
requirements of subsections (b) and (c) of rule 17f-2 of the
Investment Company Act of 1940 as of November 30, 1998, with
respect to securities reflected in the investment account of the
Trust is fairly stated, in all material respects.
This report is intended solely for the information and use of
management and the Board of Trustees of SEI Index Funds and
the Securities and Exchange Commission and should not be used
for any other purpose.
ARTHUR ANDERSEN LLP
Philadelphia, PA
January 22, 1999
