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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: |
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811-5511 |
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February 29, 2000 |
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2. State Identification Number: |
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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 |
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Other (specify): |
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3. Exact name of investment company as specified in registration statement: Variable Insurance Products Fund II: Index 500 Portfolio
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4. Address of principal executive office: (number, street, city, state, zip code) 82 Devonshire Street, Boston, MA 02109 |
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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
Report of Independent Accountants
To the Board of Trustees of:
Fidelity Concord Street Trust: Spartan U.S. Equity Index Fund
Fidelity Concord Street Trust: Spartan Total Market Index Fund
Fidelity Concord Street Trust: Spartan Extended Market Index Fund
Fidelity Commonwealth Trust: Spartan 500 Index Fund (formerly known as Spartan Market Index Fund)
Variable Insurance Products Fund II: Index 500 Portfolio
We have examined the accompanying statement of management of Fidelity Concord Street Trust: Spartan U.S. Equity Index Fund, Fidelity Concord Street Trust: Spartan Total Market Index Fund, Fidelity Concord Street Trust: Spartan Extended Market Index Fund, Fidelity Commonwealth Trust: Spartan 500 Index Fund (formerly known as Spartan Market Index Fund) and Variable Insurance Products Fund II: Index 500 Portfolio (collectively the "funds") and the assertion of management of Bankers Trust Company, sub-advisor and custodian, (collectively referred to as the "Management Statements") about the funds' compliance with the requirements of paragraphs (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 (the "Act") as of February 29, 2000. Management is responsible for ensuring the funds' compliance with those requirements. Our responsibility is to express an opinion on the Management Statements about the funds' 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 funds' 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 February 29, 2000 and with respect to agreement of security purchases and sales, for the period from September 30, 1999 (the date of our last examination) through February 29, 2000:
· Count and inspection of all securities located in the vault of Bankers Trust Company in New York, New York;
· Confirmation of all securities held by institutions in book entry form at The Federal Reserve Bank of New York, The Depository Trust Company;
· Confirmation of all securities hypothecated, pledged, placed in escrow, or out for transfer with brokers, pledgees and/or transfer agents;
· Reconciliation of all such securities to the books and records of the funds and the custodian;
· Confirmation of all repurchase agreements with brokers/banks and agreement of underlying collateral with Bankers Trust Company records; and
· Agreed selected securities purchased and securities sold or matured since our last report from the books and records of the funds to broker confirms.
We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the funds' compliance with specified requirements.
In our opinion, the Management Statements that the funds were in compliance with the requirements of paragraphs (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 as of February 29, 2000 with respect to the securities reflected in the investment accounts of the funds are fairly stated, in all material respects.
This report is intended solely for the information and use of management of the Funds and the Securities and Exchange Commission and should not be used for any other purpose.
PricewaterhouseCoopers LLP
New York, New York
July 18, 2000
July 18, 2000
PricewaterhouseCoopers LLP
160 Federal Street
Boston, MA 02110
We, as management of the funds referenced below ( the "funds"), are responsible for ensuring that Bankers Trust Company, the sub-advisor and custodian of the funds, ensures that the funds comply with the requirements of paragraphs (b) and (c) of Rule 17f-2, "Custody of Investments by Registered Management Investment Companies," under the Investment Company Act of 1940. We are also responsible for ensuring that Bankers Trust Company ensures that the funds establish and maintain effective internal controls over compliance with those requirements. We have received the accompanying representation letter from management of Bankers Trust Company dated July 13, 2000 ("Representation Letter") in which Bankers Trust Company represents that it has performed an evaluation of the funds' compliance with the requirements of paragraphs (b) and (c) of Rule 17f-2 and that the funds were in compliance with such requirements as of February 29, 2000 and from September 30, 1999 through February 29, 2000.
Based solely in reliance on the Representation Letter, we believe that the funds were in compliance with the requirements of paragraphs (b) and (c) of Rule 17f-2 of the Investment Company Act of 1940 as of February 29, 2000 and from September 30, 1999 through February 29, 2000, with respect to securities reflected in the investment accounts of the funds.
Spartan Total Market Index Fund
Spartan Extended Market Index Fund
Spartan 500 Index Fund (formerly known as Spartan Market Index Fund)
Spartan U. S. Equity Index Fund
Variable Insurance Products Fund II: Index 500 Portfolio
By: |
/s/ Maria Dwyer |
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Maria Dwyer |
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Deputy Treasurer, Fidelity Group of Funds |
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July 18, 2000 |
July 13, 2000
Ms. Maria Dwyer
Deputy Treasurer
Fidelity Management & Research Company
82 Devonshire Street
Boston, MA 02109
Dear Maria:
We, as sub-advisor and custodian of the funds referenced below (the "funds"), are responsible for ensuring that the funds comply with the requirements of paragraphs (b) and (c) of Rule 17f-2, "Custody of Investments by Registered Management Investment Companies," under the Investment Company Act of 1940. We are also responsible for ensuring that the funds establish and maintain effective internal controls over compliance with those requirements. We have performed an evaluation of the funds' compliance with the requirements of paragraphs (b) and (c) of Rule 17f-2 as of February 29, 2000 and from September 30, 1999 through February 29, 2000.
Based on our evaluation, we assert that the funds were in compliance with the requirements of paragraphs (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 as of February 29, 2000 and from September 30, 1999 through February 29, 2000, with respect to securities reflected in the investment accounts of the funds.
Spartan Total Market Index Fund
Spartan Extended Market Index Fund
Spartan 500 Index Fund (formerly known as Spartan Market Index Fund)
Spartan U. S. Equity Index Fund
Variable Insurance Products Fund II: Index 500 Portfolio
By: |
/s/Robert May |
/s/Dean Barr |
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Robert May |
Dean Barr |
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VP- Risk Management, Bankers Trust |
CIO, Bankers Trust |
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July 13, 2000 |
July 12, 2000 |
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