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 Fund of the 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 29, 1999 and from April 30, 1999 (last examination date)
through October 29, 1999.
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 29, 1999 and from April 30, 1999 through October 29,
1999, with respect to securities reflected in the investment account of the
Trust.
/S/ KATHIE MALLEY
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Kathie Malley, Investment Bank Manager
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<S> <C> <C> <C>
FUND NAME STATE FILING TYPE FILE NUMBER
[Adopted in Release No. IC-17085 (84,434), effective September 25, 1989, 54 F.R. 32048]
U.S. Securities and Exchange Commission
Washington DC 20549
FORM N-17F-2
</TABLE>
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]
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1. Investment Company Act File Number: Date Examination
Complete: 10/29/99
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
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<PAGE>
<TABLE>
<CAPTION>
<S> <C> <C> <C>
FUND NAME STATE FILING TYPE FILE NUMBER
</TABLE>
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 yours 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
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<TABLE>
<CAPTION>
<S> <C> <C> <C>
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 9942754
INDIANA A = Annual 85-0281-IC
MINNESOTA G = Good Until S R-25346.1
Minnesota Exemption A = Annual 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
KENTUCKY A = Annual M14084
LOUISIANA A = Annual 61741
OHIO O = Other 19538
OREGON A = Annual 94-1169
UTAH A = Annual 000-1864-06
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 SI23473
DELAWARE A = Annual 3220
HAWAII A = Annual
IDAHO A = Annual 30260
KANSAS A = Annual 94S0001644
MISSOURI A = Annual 205403
NEVADA A = Annual
NEW YORK O = Other S-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 I-26153
MASSACHUSETTS A = Annual 96-4288-MR
MARYLAND A = Annual SM912351
MAINE A = Annual MF-R-99-12134
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 997960
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 I-35993
KENTUCKY A = Annual M32407
LOUISIANA A = Annual 60004
MASSACHUSETTS A = Annual 96-2190-M
</TABLE>
<PAGE>
<TABLE>
<CAPTION>
<S> <C> <C> <C>
FUND NAME STATE FILING TYPE FILE NUMBER
MARYLAND A = Annual SM960358
MAINE A = Annual MF-R-99-8518
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 038542
NEW HAMPSHIRE A = Annual
NEW MEXICO A = Annual 301689
OHIO O = Other 19682
OKLAHOMA A = Annual I-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
SEI Index Funds - Bond Index Portfolio - Class A
ARIZONA A = Annual S-0019522-QUAL
IOWA A = Annual I-26154
MASSACHUSETTS A = Annual 96-4289-MR
MARYLAND A = Annual SM912352
MAINE A = Annual MF-R-99-12133
MICHIGAN A = Annual 227713
MISSISSIPPI G = Good Until S MF-88-08-010
MONTANA A = Annual 9258
NORTH DAKOTA G = Good Until S 8042
NEBRASKA A = Annual 042255
NEW HAMPSHIRE A = Annual
NEW MEXICO A = Annual 996323
SOUTH DAKOTA A = Annual 9494
TENNESSEE A = Annual RM97-2756
TEXAS G = Good Until S C-31929
VERMONT A = Annual 5/24/91-10
WASHINGTON G = Good Until S C-23777
WISCONSIN A = Annual 214370-03
</TABLE>
<PAGE>
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 Fund of SEI
Index Funds' (the "Trust's") compliance with the requirements of subsections (b)
and (c) of Rule 17f-2 under the Investment Company Act of 1940 as of October 29,
1999 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 29, 1999, and with respect to agreement of security
purchases and sales, for the period from April 30, 1999 (the date of our last
examination) through October 29, 1999:
We agreed a sample of securities shown on the books and records of SEI
Index Funds as of October 29, 1999 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 29, 1999 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 29, 1999 with brokers and the application of
alternative procedures with respect to unsettled repurchase agreement
transactions, 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.
<PAGE>
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 Fund 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 29, 1999 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.
/s/ ARTHUR ANDERSEN LLP
Philadelphia, PA
February 29, 2000
