VARIABLE INSURANCE PRODUCTS FUND II
40-17F2, 1998-08-07
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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:
					
	811-5511				December 22, 1997

 
 
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 name of investment company as specified in registration statement:
	Variable Insurance Products Fund II:  Index 500 Portfolio

4. Address of principal executive office:(number, street, city, state, zip code)
	 82 Devonshire Street, Boston, MA  02109

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



Independent Auditor's Report


To the Board of Trustees of:
Fidelity Index Fund VIP II: Index 500


We have examined the investment accounts shown on the books 
and records of the Variable Insurance Products Fund II: Index 
500 Portfolio (the "Portfolio") from the date of the transition of 
the custody to Bankers Trust Company on December 1, 1997 to 
December 22, 1997.  Our examination was made without prior 
notice to the Portfolio.

Securities owned as of the close of business on December 22, 
1997, shown by the books and records audited by us, which 
were accounted for by count or inspection, without exception, 
were located in the vault of Bankers Trust Company, except for 
securities purchased but not received, held by depositories, 
subcustodians, or out for transfer on that date as to which we 
obtained confirmations or applied other auditing procedures 
where confirmations were not received.

Our examination of the investment accounts also included, on a 
test basis, inspection of broker advices and other appropriate 
evidence in support of security transactions recorded on the 
Portfolio's records since December 1, 1997.

Because the above procedures do not constitute an audit made in 
accordance with generally accepted auditing standards, we do 
not express an opinion on the investment accounts referred to 
above.  In connection with the procedures referred to above, no 
matters came to our attention that caused us to believe that the 
investment accounts should be adjusted.  Had we performed 
additional procedures or had we performed an audit of the 
financial statements in accordance with generally accepted 
auditing standards, matters might have come to our attention 
that would have been reported to you.  This report relates only 
to the investments specified above and does not extend to any 
financial statements of the Portfolio taken as a whole.

It is understood that this report is solely for the use of 
management and the Securities and Exchange Commission and 
should not be used for any other purpose.



PricewaterhouseCoopers LLP




New York, New York
July 20, 1998



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