SEI INDEX FUNDS
40-17F2, 1999-10-01
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[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:
10/30/98
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).





















3. Exact number of investment company as specified in registration
statement: 2-97111

4. 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


3. 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 October
30, 1998, and from March 31, 1998 (last examination date) through October
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 October 30, 1998, and from March
31, 1998 (last examination date) through October  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 October
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 October 30, 1998, and with respect
to agreement of security purchases and sales, for the period
from March 31, 1998 (the date of our last examination), through
October 30, 1998:

We agreed a sample of securities shown on the books and records
of the SEI Index Funds as of October 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 October 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 October 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 October 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
December 18, 1998





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