PREMIUM PORTFOLIOS /
NSAR-B, EX-99.77B, 2001-01-02
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Report of Independent Accountants

To the Trustees and Shareholders of
 The Premium Portfolios with respect to
 its series, Large Cap Growth Portfolio,
 Small Cap Growth Portfolio, High Yield Portfolio,
 Large Cap Value Portfolio and U.S. Fixed Income Portfolio:

In planning and performing our audit of the financial  statements of The Premium
Portfolios  (the  "Portfolios")  with  respect to its  series,  Large Cap Growth
Portfolio,  Small Cap Growth  Portfolio,  High Yield Portfolio,  Large Cap Value
Portfolio and U.S.  Fixed Income  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 the Portfolios 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
in the United States of America.  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  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.


PricewaterhouseCoopers LLP
December 21, 2000


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