To the Audit Committee of the Board of Directors of
American Gas Index Fund, Inc.:
We have examined management's assertion about
American Gas Index Fund, Inc.'s (the Fund) compliance
with the requirements of subsections (b) and (c) of Rule
17f-2 under the Investment Company Act of 1940 (the
Act) as of October 13, 1999, included in the
accompanying Management Statement Regarding
Compliance with Certain Provisions of the Investment
Company Act of 1940. Management is responsible for
the Fund's compliance with those requirements. Our
responsibility is to express an opinion on management's
assertion about the Fund's 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 Fund's 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 October 13, 1999, and
with respect to agreement of security purchases and
sales, for the period from July 19, 1999, the date of our
last examination, through October 13, 1999:
Confirmation of all securities held by Rushmore
Trust and Savings, FSB (Rushmore Trust) in book
entry form for the account of the Fund;
Confirmation from Rushmore Trust that the
securities held for the account of the Fund were held
for the account of Rushmore Trust by Mellon Bank,
N.A. (Mellon), as agent for Rushmore Trust;
Confirmation with Mellon of all securities held by
Mellon in book entry form for the account of
Rushmore Trust;
Confirmation with brokers that all purchases and
sales outstanding were in agreement with the Fund's
records;
Reconciliation of all such securities to the books and
records of Rushmore Trust and the Fund;
Confirmation of all repurchase agreements with
brokers and agreement of underlying collateral with
broker's records;
Agreement of selected security purchases and
security sales since our last report from the books
and records of the Fund to broker confirmations.
We believe that our examination provides a reasonable
basis for our opinion. Our examination does not provide
a legal determination on the Fund's compliance with
specified requirements.
In our opinion, management's assertion that American
Gas Index Fund, Inc. was in compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 of
the Investment Company Act of 1940 as of October 13,
1999 with respect to securities reflected in the
investment account of the Fund is fairly stated, in all
material respects.
This report is intended solely for the information and
use of management of American Gas Index Fund, Inc.,
the Board of Directors and the Securities and Exchange
Commission and is not intended to be and should not be
used by anyone other than these specified parties.
Deloitte & Touche LLP
Princeton, New Jersey
October 26, 1999
Management Statement Regarding
Compliance with
Certain Provisions of the Investment
Company Act of 1940
We, as members of management of American Gas Index
Fund, Inc. (the Fund), 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 effective internal controls
over compliance with those requirements. We have
performed an evaluation of the Fund's compliance with
the requirements of subsections (b) and (c) of Rule 17f-2
as of October 13, 1999 and from July 19, 1999 (the date
of Deloitte & Touche LLP's last examination) through
October 13,1999.
Based on this evaluation, we assert that the Fund was in
compliance with the requirements of subsections (b) and
(c) of Rule 17f-2 of the Investment Company Act of
1940 as of October 13, 1999 and from July 19, 1999 (the
date of Deloitte & Touche LLP's last examination)
through October 13, 1999, with respect to securities
reflected in the investment accounts of American Gas
Index Fund, Inc.
Richard J. Garvey
Chairman
Timothy N. Coakley
Vice President
