Report of Independent Accountants
October 4, 2000
To the Board of Trustees of
JNL Series Trust
We have examined management's assertion about the compliance by the following
Series: JNL/S&P Conservative Growth Series I, JNL/S&P Conservative Growth Series
II, JNL/S&P Conservative Growth Series III, JNL/S&P Moderate Growth Series I,
JNL/S&P Moderate Growth Series II, JNL/S&P Moderate Growth Series III, JNL/S&P
Aggressive Growth Series I, JNL/S&P Aggressive Growth Series II, JNL/S&P
Aggressive Growth Series III, JNL/S&P Very Aggressive Growth Series I, JNL/S&P
Very Aggressive Growth Series II, JNL/S&P Equity Growth Series I, JNL/S&P Equity
Growth Series II, JNL/S&P Equity Aggressive Growth Series I, and JNL/S&P Equity
Aggressive Growth Series II (collectively the "Series"') of the JNL Series Trust
(the "Trust") with the requirements of subsections (b) and (c) of Rule 17f-2
under the Investment Company Act of 1940 (the "Act") as of August 31, 2000
included in the accompanying "Management Statement Regarding Compliance with
Certain Provisions of the Investment Company Act of 1940". Management is
responsible for the Trust's compliance with those requirements. Our
responsibility is to express an opinion on management's assertion about the
Trust's compliance based on our examination.
Our examination was conducted in accordance with attestation standards
established by the American Institute of Certified Public Accountants and,
accordingly, included examining, on a test basis, evidence about the Trust'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 August 31, 2000 and the period from December
31, 1999 (the date of last examination) through August 31, 2000 with respect to
agreement of purchases and sales of securities and similar investments, without
prior notice to management:
- Comparison of the number of shares of the Underlying Funds held in the
investment portfolio of each of the Series to the shareholder records of
each of the Underlying Funds, noting the amounts were in agreement in all
cases. The Series' investment portfolios are entirely comprised of shares
in other series of the JNL Series Trust (the "Underlying Funds");
- For each of the Underlying Funds, compared the total fund shares
outstanding per the shareholder records to the total fund shares
outstanding per the Underlying Funds' general ledger noting the amounts
were in agreement.
- For each Series, tested one day's investment transaction activity by
observing that the dollar value and share value of each Series' investment
transactions were properly recorded in the shareholder records of the
appropriate Underlying Funds. In addition, we observed that the cash
activity total for each of these investment transactions was reflected in
the third-party custodial account of the appropriate Underlying Fund.
We believe that our examination provides a reasonable basis for our opinion. Our
examination does not provide a legal determination on the Trust's compliance
with specified requirements.
In our opinion, management's assertion that the Trust was in compliance with the
above mentioned provisions of Rule 17f-2 of the Investment Company Act of 1940
as of August 31, 2000 is fairly stated, in all material respects.
This report is intended solely for the information and use of management of JNL
Series Trust and Securities and Exchange Commission and should not be used for
any other purpose.
/s/PricewaterhouseCoopers LLP
PricewaterhouseCoopers LLP