INDEPENDENT AUDITORS' REPORT
The Board of Directors
American Century Capital Portfolios, Inc.:
In planning and performing our audits of the financial statements of Equity
Income Fund, Value Fund, Real Estate Fund, Equity Index Fund, Small Cap Value
Fund and Large Cap Value Fund, the six funds comprising American Century Capital
Portfolios, Inc. (the "Company"), for the year ended March 31, 2000 (for the
period July 31, 1999 through March 31, 2000 for Large Cap Value Fund) (on which
we have issued our reports dated May 12, 2000), we considered its internal
control, including control activities for 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, and
not to provide assurance on the Company's internal control.
The management of the Company 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 accounting principles generally
accepted in the United States of America. Those controls include the
safeguarding of assets against unauthorized acquisition, use, or disposition.
Because of inherent limitations in any internal control, misstatements due
to error or fraud may occur and not be detected. Also, projections of any
evaluation of internal control to future periods are subject to the risk that
the internal control may become inadequate because of changes in conditions or
that the degree of compliance with policies or procedures deteriorate.
Our consideration of the Company's 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 one or
more of the internal control components does not reduce to a relatively low
level the risk that misstatements due to error or fraud 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 the
Company's internal control and its operation, including controls for
safeguarding securities, that we consider to be material weaknesses as defined
above as of March 31, 2000.
May 12, 2000
