STRATUS FUND INC
40-17F2, 1998-09-28
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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)



Date examination completed:  April 30, 1998



1.    Investment Company Act File Number:            811-6259


2.    State Identification Number:                   NE


3.    Address of principal executive office:         Stratus Fund, Inc.
                                                     200 Centre Terrace
                                                     1225 L Street
                                                     Lincoln, NE  68508


<PAGE>



Board of Directors
Stratus Fund, Inc.
200 Centre Terrace
1225 L Street
Lincoln, Nebraska

To the Board of Directors of:

Portfolios of Stratus Fund, Inc. (Fund)            File No.

        Capital Appreciation Portfolio             811-6259
        Intermediate Government Bond Portfolio     811-6259
        Growth Portfolio                           811-6259
        Government Securities Portfolio            811-6259
        International Portfolio                    811-6259

We have examined the  investment  accounts shown by the books and records of the
investment  companies  listed above (the Funds) for the period from  November 1,
1997 to April 30, 1998.  Our  examination  was made without  prior notice to the
Funds.  Our  examination   included   agreement  of  an  analysis  of  portfolio
transactions  recorded from November 1, 1998 to April 30, 1998 in the investment
accounts to supporting  records and  verification  of a sample of such portfolio
security transactions to supporting records and documentation.  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.

Union Bank & Trust Company (Union Bank), located in Lincoln, Nebraska, a related
entity, is custodian of the Funds' securities. Union Bank represented to us that
the securities owned by the Funds on April 30, 1998 were held for the account of
Union Bank by Fifth Third Bank, located in Cincinnati,  Ohio, or, in the case of
Fund investments in other  registered  investment  companies,  by the investment
company.  We obtained  confirmations  from Fifth Third Bank and other registered
investment  companies of the securities  held for the Fund as of April 30, 1998.
We determined that securities, identified by such records as the property of the
Funds,  were in agreement with the Funds'  records of securities  owned at April
30, 1998.

Because the above  procedures  do not  constitute  an audit 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  specified  accounts  should be adjusted.  Had we performed  additional
procedures or had we audited the financial statements of the Funds 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 the financial  statements of
any of the Funds, taken as a whole.


Deloitte & Touche LLP
Lincoln, Nebraska
June 10, 1998



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