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: March 31, 1999
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
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INDEPENDENT ACCOUNTANTS' REPORT
To the Board of Directors of
Stratus Fund, Inc.
Lincoln, Nebraska
We have examined management's assertion, included in its representation letter
dated June 18, 1999, about Stratus Fund, Inc.'s (the "Fund's") compliance with
the requirements of subsections (b) and (c) of Rule 17f-2 under the Investment
Company Act of 1940 ("the Act") as of March 31, 1999. As discussed in that
representation letter, 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 Company'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 March 31, 1999, and with respect to agreement of security
purchases and sales, for the period from December 1, 1998 through March 31,
1999:
o Confirmation of all securities held by institutions in book entry form by
Fifth Third Bank;
o Reconciliation of all such securities to the books and records of the Fund
and Fifth Third Bank;
o Agreement of five security purchases and four security sales or maturities
since our last report from the books and records of the Funds 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 Stratus 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 March 31, 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
Stratus Fund, Inc. and the Securities and Exchange Commission and is not
intended to be and should not be used for any other purpose.
DELOITTE & TOUCHE LLP
June 18, 1999
Lincoln, Nebraska
