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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 May 11, 1999
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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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[PRICEWATERHOUSECOOPERS LETTERHEAD]
INDEPENDENT ACCOUNTANTS' REPORT
To the Trustees of the AmSouth Variable Insurance Funds
We have examined management's assertion about the AmSouth Variable Insurance
Funds' (the Funds') (comprising of the Variable Equity Income fund and the
Select Equity Variable Annuity Fund) compliance with the requirements of
subsection (b) and (c) of Rule 17f-2 under the Investment Company Act of 1940 as
of May 11, 1999, included in the accompanying Management Statement Regarding
Compliance With Certain Provisions of the Investment Company Act of 1940.
Management is responsible for the AmSouth Variable Insurance Funds' compliance
with those requirements. Our responsibility is to express an opinion on
management's assertion about the AmSouth Variable Insurance Funds' 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 Funds' 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 May 11, 1999, with respect to the securities of the AmSouth
Variable Insurance Funds:
o Count and inspect all securities located in the vault of AmSouth Bank
without prior notice to management;
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 Bank;
o Confirmation, or other procedures as we consider necessary, of all
securities out for transfer with brokers;
o Confirmation, or other procedures as we deemed necessary, of all variable
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 Variable Insurance Funds and AmSouth Bank.
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[PRICEWATERHOUSECOOPERS LETTERHEAD]
We believe that our examination provides a reasonable basis for our opinion. Our
examination does not provide a legal determination on the AmSouth Variable
Insurance Funds' compliance with specified requirements.
In our opinion, management's assertion that the AmSouth Variable Insurance Funds
were in compliance with the requirements of subsections (b) and (c) of Rule
17f-2 of the Investment Company Act of 1940 as of May 11, 1999, with respect to
securities reflected in the investment accounts of the AmSouth Variable
Insurance Funds is fairly stated, in all material respects.
This report is intended for the information and use of management of the AmSouth
Variable Insurance Funds and the Securities and Exchange Commission and should
not be used for any other purpose.
/s/ PricewaterhouseCoopers LLP
August 31, 1999
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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 Variable Insurance Funds (the Funds)
(comprising of the Variable Equity Income fund and the Select Equity Variable
Annuity 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 AmSouth Variable Insurance
Funds' compliance with the requirements of Rule 17f-2 as of May 11, 1999. Based
on this evaluation, we assert that the Company was in compliance with the
provisions of subsection (b) and (c) of Rule 17f-2 of the Investment Company Act
of 1940 as of May 11, 1999 with respect to securities reflected in the
investment account of the AmSouth Variable Insurance Funds.
AmSouth Variable Insurance Funds
