REPORT OF INDEPENDENT ACCOUNTANTS
February 7, 2000
To the Board of Trustees of
JNL Series Trust
We have examined management's assertion about JNL/S&P Conservative Growth Series
I, JNL/S&P Conservative Growth Series II, JNL/S&P Moderate Growth Series I,
JNL/S&P Moderate Growth Series II, JNL/S&P Aggressive Growth Series I, JNL/S&P
Aggressive Growth Series II, 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") compliance with the requirements of subsections (b) and (c) of
Rule 17f-2 under the Investment Company Act of 1940 (the "Act") as of October
29, 1999 included in the accompanying "Management Statement Regarding Compliance
with Certain Provisions of the Investment Company Act of 1940." Management is
responsible for the Series' compliance with those requirements. Our
responsibility is to express an opinion on management's assertion about the
Series' 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 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 October 29, 1999 and the period from September 30, 1999 (the
date of last examination) through October 29, 1999 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 Series' compliance
with specified requirements.
In our opinion, management's assertion that Series were in compliance with the
above mentioned provisions of Rule 17f-2 of the Investment Company Act of 1940
as of October 29, 1999 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
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MANAGEMENT STATEMENT REGARDING COMPLIANCE WITH
CERTAIN PROVISIONS OF THE INVESTMENT COMPANY ACT OF 1940
We, as members of management of JNL Series Trust (the "Trust"), are responsible
for complying with the requirements of subsections (b) and (c) of Rule 17f-2,
Custody of Investments by Registered Management Investment Companies, of the
Investment Company Act of 1940. We are also responsible for establishing and
maintaining an effective internal control structure over compliance with those
requirements. We have performed an evaluation of the Trust's compliance with the
requirements of subsections (b) and (c) of Rule 17f-2 as of October 29, 1999.
Based on this evaluation, we assert that the Trust was in compliance with those
provisions of Rule 17f-2 of the Investment Company Act of 1940 as of October 29,
1999 with respect to securities and similar investments reflected in the
investment account of the Trust.
JNL Series Trust
By:
/s/ Mark D. Nerud
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Mark D. Nerud
Vice President
JNL Series Trust
/s/ William Simon
- --------------------------------
William Simon
Manager of Mutual Fund Accounting
Jackson National Financial Services, LLC
