INDEPENDENT ACCOUNTANTS' REPORT
To the Board of Directors of
Stratus Fund, Inc.
Lincoln, Nebraska
We have examined management's assertion 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 January 31,
2000 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 January 31, 2000, and with respect to agreement of security
purchases and sales, for the period from October 1, 1999 through January 31,
2000:
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 three security purchases and two 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 January 31, 2000 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.
/s/ Deloitte & Touche LLP
March 24, 2000
Lincoln, Nebraska
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MANAGEMENT STATEMENT REGARDING COMPLIANCE
WITH CERTAIN PROVISIONS OF THE
INVESTMENT COMPANY ACT OF 1940
March 24, 2000
Deloitte & Touche LLP
1040 NBC Center
Lincoln, NE 68508
Gentlemen:
In connection with your attestation engagement as of January 31, 2000, relating
to Stratus Fund, Inc.'s (the Fund) compliance with Securities and Exchange
Commission Rule 17f-2, we confirm, to the best of our knowledge and belief, the
following representations made to you during your procedures:
1. We, as members of management of 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.
2. We are also responsible for establishing and maintaining effective internal
controls over compliance with those requirements.
3. We have performed an evaluation of the Fund's compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 as of January 31,
2000 and from October 1, 1999 through January 31, 2000.
4. 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 January 31, 2000 and from October 1, 1999 through January 31, 2000,
with respect to securities reflected in the investment account of the Fund.
5. We have no knowledge of significant matters that are contrary to your
findings.
/s/ Chad Melcher
Chad Melcher
Vice President Trust Operations Officer
