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: September 30, 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 November 24, 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 September 30, 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 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 September 30, 1999, and with respect to agreement of security
purchases and sales, for the period from July 1, 1999 through September 30,
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 two security purchases and three 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 September 30, 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 by anyone other than these specified
parties.
November 24, 1999
Lincoln, Nebraska
