EX-99.77B Accountant's Report on Internal Control
Independent Auditors' Report on Internal Accounting Control
The Board of Directors and Shareholders
Advantus International Balanced Fund, Inc.:
In planning and performing our audit of the financial statements of
Advantus International Balanced Fund, Inc. for the year ended
September 30, 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 the
internal control.
The management of Advantus International Balanced Fund, Inc. 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 the internal control would not necessarily
disclose all matters in the 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 errors 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 internal
control and its operation, including controls for safeguarding
securities, that we consider to be material weaknesses as defined
above.
This report is intended solely for the information and use of
management, the Board of Directors of Advantus International
Balanced 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.
KPMG LLP
Minneapolis, Minnesota
November 10, 2000
