ADJUSTABLE RATE SECURITIES PORTFOLIOS
NSAR-B, EX-99.OPINION, 2000-12-28
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              REPORT OF INDEPENDENT ACCOUNTANTS



To the Shareholders and Board of Directors of
Adjustable Rate Securities Portfolios

In planning and performing our audit of the financial
statements of Adjustable Rate Securities Portfolio for the
year ended October 31, 2000, we considered its internal
control, including controls over safeguarding securities, in
order to determine our auditing procedures for the purpose
of expressing our opinion on the financial statements and to
comply with the requirements of Form N-SAR, not to provide
assurance on internal control.

The management of Adjustable Rate Securities Portfolio is
responsible for establishing and maintaining internal
control. In fulfilling this responsibility, estimates and
judgments by management are required to assess the expected
benefits and related costs of controls.  Generally, controls
that are relevant to an audit pertain to the entity's
objective of preparing financial statements for external
purposes that are fairly presented in conformity with
generally accepted accounting principles.  Those controls
include the safeguarding of assets against unauthorized
acquisition, use, or disposition.

Because of inherent limitations in internal control, errors
or irregularities may occur and not be detected.  Also,
projection of any evaluation of internal control to future
periods is subject to the risk that it may become inadequate
because of changes in conditions or that the effectiveness
of the design and operation may deteriorate.

Our consideration of internal control would not necessarily
disclose all matters in internal control that might be
material weaknesses under standards established by the
American Institute of Certified Public Accountants. A
material weakness is a condition in which the design or
operation of any specific internal control component does
not reduce to a relatively low level the risk that errors or
irregularities in amounts that would be material in relation
to the financial statements being audited may occur and not
be detected within a timely period by employees in the
normal course of performing their assigned functions.
However, we noted no matters involving internal control,
including controls over safeguarding securities that we
consider to be material weaknesses as defined above as of
October 31, 2000.


This report is intended solely for the information and use
of management and the Securities and Exchange Commission.



PRICEWATERHOUSECOOPERS LLP




San Francisco, California
December 20, 2000




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