Report of Independent Accountants
To the Trustees of
The Victory Portfolios:
In planning and performing our audits of the financial statements of The
Victory Portfolios for the year ended October 31, 2000 we considered its
internal control, including controls over 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 internal control.
The management of The Victory Portfolios is responsible for establishing
and maintaining internal control. In fulfilling this responsibility,
estimates and judgements 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 may 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 internal control would not necessarily disclose all
matters in 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 any specific internal control component does not reduce to a
relatively low level the risk that errors or irregularities 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 internal control, including controls over
safeguarding securities, that we consider to be material weaknesses as
defined above as of October 31, 2000.
This report is intended solely for the information and use of management
and the Trustees of The Victory Portfolios and the Securities and Exchange
Commission and is not intended to be and should not be used by anyone
other than these specified parties.
December 18, 2000
