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SECURITIES AND EXCHANGE COMMISSION --------------------------
WASHINGTON, D.C. 20549 OMB Approval
FORM N-17f-2 --------------------------
OMB Number: 3235-0360
Certificate of Accounting of Securities and Similar Expires: July 31, 1994
Investment in the Custody of Estimated average burden
Management Investment Companies hours per response... 0.05
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
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1. Investment Company Act File Number: Date examination completed
811-8644 March 2, 1998
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2. State identification Number: N/A
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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 representation statement:
Variable Insurance Funds
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4. Address of principal executive office (number, street, city, state, zip code):
3435 Stelzer Road, Columbus, Ohio 43219
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|Coopers |COOPERS & LYBRAND L.L.P.
|& Lybrand |
|a professional services firm
INDEPENDENT ACCOUNTANT'S REPORT
To the Trustees of the AmSouth Equity Income VIF
We have examined management's assertion about the AmSouth Equity Income VIF's
(the Fund's) compliance with the requirements of subsection (b) and (c) of Rule
17f-2 under the Investment Company Act of 1940 as of March 2, 1998, included in
the accompanying Management Statement Regarding Compliance With Certain
Provisions of the Investment Company Act of 1940. Management is responsible for
the AmSouth Equity Income VIF's compliance with those requirements. Our
responsibility is to express an opinion on management's assertion about the
AmSouth Equity Income VIF'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 Fund'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 2, 1998, with respect to the securities of the AmSouth
Equity Income VIF:
o Count and inspect all securities located in the vault of AmSouth Bank;
o Confirmation, or other procedures as we considered necessary, of all
securities held in book entry form by the Federal Reserve Bank of Atlanta,
Depository Trust Company, or Chase Manhattan Bank;
o Confirmation, or other procedures as we deemed necessary, of all mutual
fund investments with transfer agents;
o Confirmation, or other procedures we deemed necessary, of all repurchase
agreements with brokers/banks and agreement of underlying collateral with
AmSouth Bank's records; and
o Reconciliation of all such securities to the books and records of the
AmSouth Equity Income VIF and AmSouth Bank.
We believe that our examination provides a reasonable basis for our opinion. Our
examination does not provide a legal determination on the AmSouth Equity Income
VIF's compliance with specified requirements.
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In our opinion, management's assertion that the AmSouth Equity Income VIF was
in compliance with the above-mentioned provisions of Rule 17f-2 of the
Investment Company Act of 1940 as of March 2, 1998, except for noncompliance as
described in management's report, is fairly stated, in all material respects.
This report is intended for the information and use of management of the
AmSouth Equity income VIF and the Securities and Exchange Commission and should
not be used for any other purpose.
/s/ Coopers & Lybrand L.L.P.
Columbus, Ohio
June 17, 1998
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MANAGEMENT STATEMENT REGARDING COMPLIANCE WITH CERTAIN PROVISIONS
OF THE INVESTMENT COMPANY ACT OF 1940
We, as members of management of the AmSouth Equity Income VIF (the Fund) are
responsible for complying with the requirements of Rule 17f-2, "Custody of
Investments by Registered Management Investments Companies," of the Investment
Company Act of 1940. We are also responsible for establishing and maintaining an
effective internal control over compliance with Rule 17f-2 requirements. We have
performed an evaluation of the Fund's compliance with the requirements of Rule
17f-2 as of March 2, 1998. Based on this evaluation, we assert that the Fund was
in compliance with the provisions of subsection (b) and (c) of Rule 17f-2 of the
Investment Company Act of 1940 as of March 2, 1998 with respect to securities
reflected in the investment account of the AmSouth Equity Income VIF.
AmSouth Equity Income VIF
