PIC SMALL CAP PORTFOLIO
NSAR-B, EX-99, 2001-01-12
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Report of Independent Accountants

To the Board of Trustees and Holders of Beneficial
Interests
of  PIC Small Cap Portfolio

In planning and performing our audit of the financial
statements of PIC Small Cap Portfolio for the year
ended October 31, 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, not to provide
assurance on internal control.

The management of PIC Small Cap 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 fraud may occur and not be detected.  Also,
projection of any evaluation of internal control to
future periods is subject to the risk that controls may
become inadequate because of changes in conditions
or that the effectiveness of their 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 one or
more of the internal control components does not
reduce to a relatively low level the risk that
misstatements caused by 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 internal
control and its operation, including controls for
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 the Board of Trustees, management 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/ PricewaterhouseCoopers LLP


New York,  New York
     December 15, 2000



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