FORM N-17f-2
[As adopted in Release No. IC-17085, July 26, 1998, effective
September 25, 1998, 54 F.R. 32048]
U.S. Securities and Exchange Commission
Washington, D.C. 20549
FORM N-17f-2
Certificate of Accounting of Securities and Similar Investments
in the Custody
of Management Investment Companies
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
_________________________________________________________________
__________
1. Investment Company Act File Number: Date
examination completed:
811-
2. State Identification Number:
AL AK AZ AR CA CO
CT DE DC FL GA HI
ID IL IN IA KS KY
LA ME MD MA MI MN
MS MO MT NE NV NH
NJ NM NY NC ND OH
OK OR PA RI SC SD
TN TX UT VT VA WA
WV WI WY PUERTO RICO
Other (specify):
3. Exact number of investment company as specified in
registration statement:
4. Address of principal executive office: (number, street,
city, state, zip code)
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, D.C., one copy with the regional office for 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, U.S. Securities and Exchange
Commission, 450 Fifth Street, N.W., Washington, D.C. 20549 and
Gary Waxman, Clearance Officer, Office of Management and Budget,
Room 3208 New Executive Office Building, Washington, D.C. 20503
The Spain Fund
500 Plaza Drive Secaucus NJ 07094
(201) 319-4000
Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940
We, as members of management of The Spain Fund, Inc. (the
"Company"), 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 an effective internal control
structure over compliance with the requirements of subsections
(b) and (c) of Rule 17f-2 as of November 28, 1997.
Except as indicated below, all securities owned by the company
as reflected in the accounting records of the Company at
November 28, 1997, and which are denoted by such records as
being under the control of Banco Bilbao Vizcaya, S.A. (" the
subcustodian") were held in book entry form by the Spanish
central depository, Servicio de Compensacion y Liquidacion de
Valores ("SCL"). The securities maintained by SCL are held in
an omnibus account on behalf of the subcustodian. At November
28, 1997, the subcustodian physically held 1,511,470 shares of
Unidad Editorial, S.A. Series A.
Based on this evaluation as of November 28, 1997, we assert that
the Company was in compliance with those provisions of Rule
17f-2 of the Investment Company Act of 1940, with respect to
securities reflected in the investment account of the Company.
The Spain Fund, Inc.
By:
____________________________________
Name/Title
____________________________________
Name/Title
