UNITED STATES
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]
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1. Investment Company Act File Number: Date examination completed:
811-7394 March 31, 1998
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2. State identification Number:
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AL AK AZ AR CA CO
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CT DE DC FL GA HI
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ID IL IN IA KS KY
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LA ME MD MA MI MN
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MS MO MT NE NV NH
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NJ NM NY NC ND OH
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OK OR PA RI SC SD
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TN TX UT VT VA WA
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WV WI WY PUERTO RICO
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Other (specify):
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3. Exact name of investment company as specified in registration statement:
INTERNATIONAL EQUITY PORTFOLIO
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5. Address of principal executive office (number, street, city, state, zip
code):
Dean Harris, 1 Chase Square - 7th Floor, Rochester, New York, 14643
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INSTRUCTIONS
This Form must be completed by investment companies that have custody of
securities or similar investments.
Investment Company
1. All items must be completed by the investment company.
2. Give this Form to the independent public accountant who, in compliance with
Rule 17f-2 under the Act and applicable state law, examines securities and
similar investments in the custody of the investment company.
Accountant
3. Submit this Form to the Securities and Exchange Commission and appropriate
state securities administrators when filing the certificate of accounting
required by Rule 17f-2 under the Act and applicable state law. File the
original and one copy with the Securities and Exchange Commission's
principal office in Washington, D.C., one copy with the regional office for
the region in which the investment company's principal business operations
are conducted, and one copy with the appropriate state administrator(s), if
applicable.
THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT
SEC 2198 (11-91)
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Report of Independent Accountants
June 24, 1998
To the Trustees of
International Equity Portfolio
We have examined management's assertion about International Equity Portfolio's
(the "Company") compliance with the requirements of subsections (b) and (c) of
Rule 17f-2 under the Investment Company Act of 1940 ("the Act") as of March 31,
1998 included in the accompanying Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940. Management is
responsible for the Company's compliance with those requirements. Our
responsibility is to express an opinion on management's assertion about the
Company'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 Company'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 March 31, 1998, and the period from August 31, 1997 (the date of
last examination) through March 31, 1998 with respect to agreement of purchases
and sales of securities and similar investments, without prior notice to
management:
o Testing of securities and similar investments held in book entry form by
The Depository Trust Company via evaluation of the reconciliation
procedures used by the Custodian and disposition of any reconciling items
related to the Company's positions;
o Testing of the reconciliation of securities and similar investments,
prepared by management of the Company, between the books and records of the
Company and the Custodian;
o For global securities held in book entry form by sub-custodians outside of
the United States:
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o Testing of the reconciliation of custody records, prepared by
management of the Company, between The Chase Manhattan Bank,
Bournemouth, England, the primary custodian outside of the United
States, and the corresponding sub-custodians;
o Testing of the reconciliation of securities and similar investments
from The Chase Manhattan Bank, Bournemouth, England to the records of
The Chase Manhattan Bank, New York;
o Where the Chase Manhattan Bank, New York, engaged a related
sub-custodian, we reviewed the reconciliation prepared by the
sub-custodian, between the sub-custodian's positions and the local
depository, and confirmed positions with such depository, whether the
positions were in the individual portfolio's name or in an omnibus
account.
We believe that our examination provides a reasonable basis for our opinion. Our
examination does not provide a legal determination on the Company's compliance
with specified requirements.
In our opinion, management's assertion that International Equity Portfolio was
in compliance with the above mentioned provisions of Rule 17f-2 of the
Investment Company Act of 1940 as of March 31, 1998 is fairly stated, in all
material respects.
This report is intended solely for the information and use of management of
International Equity Portfolio and Securities and Exchange Commission and should
not be used for any other purpose.
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Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940
We, as members of management of International Equity Portfolio (the "Company"),
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. We are also responsible for
establishing and maintaining an effective internal control structure over
compliance with those requirements. We have performed an evaluation of the
Company's compliance with the requirements of subsections (b) and (c) of Rule
17f-2 as of March 31, 1998.
Based on this evaluation, we assert that the Company was in compliance with
those provisions of Rule 17f-2 of the Investment Company Act of 1940 as of March
31, 1998 with respect to securities and similar investments reflected in the
investment account of the Company.
International Equity Portfolio
By:
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Martin R. Dean
Treasurer
International Equity Portfolio
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Colleen McCoy
Vice President
Chase Manhattan Bank
