<PAGE>
[RUSSELL INSURANCE FUNDS LETTERHEAD]
May 3, 2000
VIA ELECTRONIC TRANSMISSION
- ---------------------------
Securities and Exchange Commission
450 5th Street, N.W.
Judiciary Plaza
Washington, D.C. 20549
Re: Russell Insurance Funds (the "Registrant") -- Post Effective Amendment No.
8 Under the 1933 Act and Amendment No. 12 Under the 1940 Act
File No. 33-18030, 1933 Act; File No. 811-5371, 1940 Act
Ladies and Gentlemen:
I serve as Legal Counsel to Russell Insurance Funds (the "Registrant). I also
serve as an officer of the Registrant.
As Legal Counsel, I have reviewed the Registrant's Post-Effective Amendment No.
8 to the Registrant's Registration Statement. I hereby certify that the form of
prospectus and Statement of Additional Information which would have been filed
pursuant to Paragraph (c) of Rule 497 does not differ from that contained in the
Post-Effective Amendment No. 8 and is therefore eligible for filing pursuant to
Paragraph (j) of Rule 497. I further certify that the text of Post-Effective
Amendment No. 8 was filed electronically with the Securities and Exchange
Commission under Paragraph (b) of Rule 485 of the Securities Act of 1933 on
April 27, 2000 with an effective date of April 28, 2000.
Sincerely,
/s/
Mary Beth Rhoden
Staff Counsel
