-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, Sr0ltdRodO05VBZ9WpKX+qKKbJ5/4yN2gh4e5F7tffEKdr1hNaHPE+xF3l76jLaT 1jtSBJz/3deaaPSQvb5iAA== 0000717854-09-000012.txt : 20090826 0000717854-09-000012.hdr.sgml : 20090826 20090826132346 ACCESSION NUMBER: 0000717854-09-000012 CONFORMED SUBMISSION TYPE: N-Q PUBLIC DOCUMENT COUNT: 2 CONFORMED PERIOD OF REPORT: 20090630 FILED AS OF DATE: 20090826 DATE AS OF CHANGE: 20090826 EFFECTIVENESS DATE: 20090826 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ELFUN INTERNATIONAL EQUITY FUND CENTRAL INDEX KEY: 0000817656 IRS NUMBER: 061205244 STATE OF INCORPORATION: CT FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: N-Q SEC ACT: 1940 Act SEC FILE NUMBER: 811-05216 FILM NUMBER: 091035843 BUSINESS ADDRESS: STREET 1: 3001 SUMMER STREET CITY: STAMFORD STATE: CT ZIP: 06905 BUSINESS PHONE: 203-708-3133 MAIL ADDRESS: STREET 1: 3001 SUMMER STREET CITY: STAMFORD STATE: CT ZIP: 06905 FORMER COMPANY: FORMER CONFORMED NAME: ELFUN GLOBAL FUND DATE OF NAME CHANGE: 19920703 0000817656 S000011817 ELFUN INTERNATIONAL EQUITY FUND C000032294 Elfun International Equity Fund eglbx N-Q 1 elfint.txt ELFUN INTERNATIONAL FUND - SCHEDULE OF INVESTMENTS JUNE 30, 2009 OMB APPROVAL OMB Number: 3235-0578 Expires: April 30, 2010 Estimated average burden hours per response:10.50 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-05216 - ----------------------------------------------------------------- Elfun International Equity Fund - ------------------------------------------------------------------ (Exact name of registrant as specified in charter) 3001, SUMMER STREET,STAMFORD, CONNECTICUT, 06905 - ------------------------------------------------------------------- (Address of principal executive offices) (Zip code) GE ASSET MANAGEMENT,3001, SUMMER STREET,STAMFORD,CONNECTICUT, 06905 - ------------------------------------------------------------------ (Name and address of agent for service) Registrant"s telephone number, including area code: 800-242-0134 ---------------------------- Date of fiscal year end: 12/31 --------------------------- Date of reporting period: : 06/30/09 ------------------------- ITEM 1. SCHEDULE OF INVESTMENTS Elfun International Equity Schedule of Investments (dollars in thousands) - June 30, 2009 (unaudited) The securities information regarding holdings, allocations and other characteristics are presented to illustrate examples of securities that the Fund has bought and the diversity of areas in which the Fund may invest as of a particular date. It may not be representative of the Fund's current or future investments and should not be construed as a recommendation to purchase or sell a particular security.
Number of Shares Value Common Stock - 98.8% - -------------------------------------------------------------------------------------------------------------------------- Australia - 2.9% Brambles Ltd. 887,010 $ 4,274 Paladin Energy Ltd. 488,797 1,948 (a) Telstra Corporation Ltd. 452,029 1,239 7,461 Brazil - 2.1% Petroleo Brasileiro S.A. ADR 73,567 2,454 Vale S.A. 182,887 2,807 5,261 Canada - 1.9% Kinross Gold Corp. 55,650 1,016 Potash Corp of Saskatchewan Inc. 40,312 3,766 4,782 Chile - 0.3% Sociedad Quimica y Minera de Chile S.A. ADR (Series B) 17,689 640 China - 0.4% China Mobile Ltd. 109,191 1,093 Denmark - 0.4% G4S PLC 313,278 1,074 Finland - 1.3% Nokia OYJ 230,831 3,380 France - 15.5% Alstom S.A. 13,747 811 AXA S.A. 74,914 1,407 BNP Paribas 107,792 6,993 Cie Generale d'Optique Essilor International S.A. 69,250 3,301 Credit Agricole S.A. 261,001 3,249 Danone 16 - (a) GDF Suez 42,180 1,570 Groupe Danone 118,938 5,869 Total S.A. 106,930 5,771 Unibail-Rodamco (REIT) 4,639 691 Veolia Environnement 137,399 4,045 Vinci S.A. 51,812 2,324 Vivendi 150,263 3,590 39,621 Germany - 7.6% Adidas AG 33,799 1,285 Bayer AG 76,134 4,082 Deutsche Boerse AG 20,425 1,584 E.ON AG 78,200 2,766 Linde AG 34,971 2,866 Metro AG 48,491 2,314 RWE AG 10,467 824 Siemens AG (Regd.) 54,819 3,780 19,501 Greece - 0.2% Hellenic Telecommunications Organization S.A. 30,907 473 Hong Kong - 0.9% Esprit Holdings Ltd. 205,371 1,151 Sun Hung Kai Properties Ltd. 84,550 1,059 2,210 India - 1.3% ICICI Bank Ltd. 39,874 604 Larsen & Toubro Ltd. 86,333 2,830 3,434 Ireland - 0.7% CRH PLC 81,862 1,866 Italy - 2.6% ENI S.p.A. 140,926 3,331 Intesa Sanpaolo S.p.A. 745,510 2,400 Saipem S.p.A. 40,399 983 6,714 Japan - 17.6% East Japan Railway Co. 43,297 2,607 Mitsubishi Estate Company Ltd. 268,946 4,491 Mitsubishi Heavy Industries Ltd. 526,000 2,181 Mitsubishi UFJ Financial Group Inc. 1,058,602 6,561 Nintendo Company Ltd. 6,999 1,932 Nomura Holdings Inc. 745,075 6,286 Shiseido Company Ltd. 266,881 4,376 Sony Financial Holdings Inc. 1,456 4,025 (a) Sumitomo Metal Industries Ltd. 980,030 2,610 Sumitomo Mitsui Financial Group Inc. 52,544 2,140 The Bank of Yokohama Ltd. 374,026 2,004 Toray Industries Inc. 262,152 1,338 Toyota Motor Corp. 112,482 4,279 44,830 Mexico - 0.6% America Movil SAB de C.V. ADR (Series L) 36,892 1,428 Netherlands - 2.3% Heineken N.V. 31,949 1,185 Koninklijke Ahold N.V. 114,634 1,316 Koninklijke Philips Electronics N.V. 179,439 3,303 5,804 Singapore - 1.0% CapitaLand Ltd. 596,500 1,529 Singapore Telecommunications Ltd. 449,342 931 2,460 South Africa - 1.0% MTN Group Ltd. 169,598 2,598 South Korea - 1.4% KB Financial Group Inc. 33,863 1,138 Samsung Electronics Company Ltd. 5,250 2,440 3,578 Spain - 5.4% Banco Santander S.A. (Regd.) 709,836 8,523 Iberdrola S.A. 293,134 2,362 Telefonica S.A. 127,202 2,876 13,761 Sweden - 0.6% Hennes & Mauritz AB (Series B) 28,650 1,424 Switzerland - 11.4% ABB Ltd. (Regd.) 157,814 2,478 (a) Credit Suisse Group AG (Regd.) 91,672 4,181 Nestle S.A. (Regd.) 190,194 7,156 Novartis AG (Regd.) 96,580 3,911 Roche Holding AG 64,469 8,756 Syngenta AG 11,232 2,605 29,087 Taiwan - 1.2% Taiwan Semiconductor Manufacturing Company Ltd. 1,851,145 3,086 United Kingdom - 18.2% BG Group PLC 210,366 3,527 BHP Billiton PLC 193,205 4,340 (h) BP PLC 213,738 1,682 Diageo PLC 59,477 854 G4S PLC 492,020 1,689 HSBC Holdings PLC 392,173 3,245 Lloyds Banking Group PLC 3,259,031 3,753 National Grid PLC 503,268 4,538 Prudential PLC 426,439 2,904 Reckitt Benckiser Group PLC 128,918 5,872 Rio Tinto PLC 22,831 262 (a) Rio Tinto PLC (Regd.) 45,737 1,586 Tesco PLC 811,280 4,724 The Capita Group PLC 123,950 1,458 Vodafone Group PLC 3,043,247 5,874 46,308 Total Common Stock 251,874 (Cost $291,476)
- ------------------------------------------------------------------------------------------------------------------------------------ Other Investments - 0.0%* - ------------------------------------------------------------------------------------------------------------------------------------ GEI Investment Fund 85 (j) (Cost $154) Total Investments in Securities 251,959 (Cost $291,630) - ------------------------------------------------------------------------------------------------------------------------------------ Short-Term Investments - 0.4% - ------------------------------------------------------------------------------------------------------------------------------------ GE Money Market Fund Institutional Class 0.28% 1,031 (d,p) (Cost $1,031) Total Investments 252,990 (Cost $292,661) Other Assets and Liabilities, net - 0.8% 1,909 ----------------- NET ASSETS - 100.0% $ 254,899 ================= - ------------------------------------------------------------------------------------------------------------------------------------ Other Information - ------------------------------------------------------------------------------------------------------------------------------------
The Elfun International Equity had the following short futures contracts open at June 30, 2009 (unaudited);
Number of Current Notional Unrealized Appreciation/ Description Expiration date Contracts Value (Depreciation) - ------------------------------------------------------------------------------------------------------------------------------------ DJ Euro Stoxx 50 Index Futures 9/18/2009 16 $ (538) $ (2) FTSE 100 Index Futures 9/28/2009 3 (208) 1 Topix Index Futures 9/11/2009 2 (192) (1) ----------------- $ (2) =================
Sector Percentage (based on Market Value) - ------------------------------------------------------------------------------------------------------------------------------------ Commercial Banks 16.04% Oil, Gas & Consumable Fuels 7.40% Pharmaceuticals 6.62% Food Products 5.15% Metals & Mining 4.99% Chemicals 4.43% Wireless Telecommunication Services 4.35% Multi-Utilities 4.34% Capital Markets 4.14% Food & Staples Retailing 3.30% Insurance 3.29% Industrial Conglomerates 2.80% Real Estate Management & Development 2.80% Commercial Services & Supplies 2.78% Household Products 2.32% Diversified Telecommunication Services 2.18% Semiconductors & Semiconductor Equipment 2.18% Construction & Engineering 2.04% Electric Utilities 2.03% Personal Products 1.73% Automobiles 1.69% Media 1.42% Communications Equipment 1.34% Electrical Equipment 1.30% Healthcare Equipment & Supplies 1.30% Road & Rail 1.03% Specialty Retail 1.02% Machinery 0.86% Beverages 0.81% Software 0.76% Construction Materials 0.74% Diversified Financial Services 0.63% Professional Services 0.58% Textiles Apparel & Luxury Goods 0.51% Short-Term 0.41% Energy Equipment & Services 0.39% Real Estate Investment Trusts (REIT's) 0.27% Other Investments 0.03% ----------------- 100.00% =================
Notes to Schedules of Investments (dollars in thousands) June 30, 2009 (unaudited) - -------------------------------------------------------------------------------- (a) Non-income producing security. (b) Pursuant to Rule 144A of the Securities Act of 1933, these Securities may be resold in transactions exempt from registration, normally to qualified institutional buyers. At June 30, 2009, these securities amounted to $23,633; $3,522; $11,240 and $14,101 or 8.75%, 1.77%, 0.66% and 4.38%of net assets for the Elfun Money Market Fund, Elfun Diversified Fund, Elfun Tax-Exempt Income Fund and Elfun Income Fund respectively. These securities have been determined to be liquid using procedures established by the Board of Trustees. (c) Settlement is on a delayed delivery or when-issued basis with final maturity to be announced (TBA) in the future. (d) Coupon amount represents effective yield. (e) State Street Corp. is the parent company of State Street Bank & Trust Co., the Fund's custodian and accounting agent. (f) Principal only securities represent the right to receive the monthly principal payments on an underlying pool of mortgages. No payments of interest on the pool are passed through to the "principal only" holder. (g) Interest only securities represent the right to receive the monthly interest payments on an underlying pool of mortgages. Payments of principal on the pool reduce the value of the "interest only" holding. (h) At June 30, 2009, all or a portion of this security was pledged to cover collateral requirements for futures, options, forward foreign currency contracts and/or TBA's. (i) Variable or floating rate security. The stated rate represents the rate at June 30, 2009. (j) GEAM, the investment adviser of the Fund, also serves as investment adviser of the Trust. (k) Escrowed to maturity. Bonds are collateralized by U.S. Treasury securities which are held in escrow by a trustee and used to pay principal and interest on such bonds (l) Prerefunded. Bonds are collateralized by U.S. Treasury securities, which are held in escrow and are used to pay principal and interest on the tax-exempt issue and to retire the bonds at the earliest refunding date. (m) The security is insured by AMBAC, MBIA, FSA or FGIC. The Elfun Tax-Exempt Fund had insurance concentrations of 5% or greater as of June 30, 2009 (as a percentage of net assets) as follows: FSA 10.25% AMBAC 10.17% (n) Treasury Inflation Protected Securities. (o) Sponsored by SSgA Funds Management, Inc., an affiliate of State Street Bank & Trust Co., the Fund's custodian and accounting agent. (p) GEAM, the investment adviser of the Fund, also serves as investment adviser of the GE Money Market Fund. (q) Illiquid Securities. At June 30, 2009, these securities amounted to $18,710 and $361 or 5.82% and 0.18% of net assets for the Elfun Income and Elfun Diversified Fund respectively. These securities have been determined to be illiquid using procedures established by the Board of Trustees. (r) Coupon amount represents the coupon of the underlying mortgage securities on which monthly interest payments are based. The maturity date disclosed for fixed income securities represents the earlier of the first call date; the next interest reset date or the ultimate maturity date + Percentages are based on net assets as of June 30, 2009. * Less than 0.1% ** Amount is less than $500 Abbreviations: ADR American Depositary Receipt AMBAC AMBAC Indemnity Corporation FGIC Financial Guaranty Insurance Corporation FSA Financial Security Assurance GDR Global Depositary Receipt MBIA Municipal Bond Investors Assurance Corporation Regd. Registered REIT Real Estate Investment Trust REMIC Real Estate Mortgage Investment Conduit SPDR Standard & Poor's Depository Receipts STRIPS Separate Trading of Registered Interest and Principal of Security SECURITY VALUATION AND TRANSACTIONS The Fund's portfolio securities are valued generally on the basis of market quotations. Equity securities generally are valued at the last reported sales price on the primary market in which they are traded. Portfolio securities listed on NASDAQ are valued using the NASDAQ Official Closing Price, which may not necessarily represent the last sale price. If no sales occurred on the exchange or NASDAQ that day, the portfolio security generally is valued using the last reported bid price. Debt securities (other than short-term securities described below) generally are valued at an evaluated bid as reported by an independent pricing service. Values obtained from pricing services are based on recent trading activity and other relevant information which may include market interest rate curves, referenced credit spreads and estimated prepayment rates where applicable. In the absence of a reliable price from such a pricing service, debt securities may be valued based on dealer supplied valuations or quotations. The Fund's written or purchased options are valued at the last sales price, or if no sales occurred that day, at the last reported bid price. Short-term investments with remaining maturities of sixty days or less at the time of purchase are valued on the basis of amortized cost, which approximates market value. All assets and liabilities of the Fund that are initially expressed in foreign currency values will be converted into U.S. dollars at the WM/Reuters exchange rate computed at 11:00 a.m., Eastern time. If prices are not readily available for a portfolio security, or if it is believed that a price for a portfolio security does not represent its fair value, the security may be valued using procedures approved by the Fund's Board of Directors that are designed to establish its "fair" value. Those procedures require that the fair value of a security be established by the fair valuation committee. The fair valuation committee follows different protocols for different types of investments and circumstances. The fair value procedures may be used to value any investment by the Fund in the appropriate circumstances. Examples of the types of securities that may be fair valued include: thinly traded or illiquid investments, high-yield securities or foreign securities. Foreign securities may be valued with the assistance of an independent fair value pricing service in circumstances where it is believed that they have been or would be materially affected by events occurring after the close of the portfolio security's primary market and before the close of regular trading on the NYSE. This independent fair value pricing service uses a computerized system to appraise affected securities and portfolios taking into consideration various factors and the fair value of such securities may be something other than the last available quotation or other market price. GEAM may also separately monitor portfolio securities and, consistent with the Fund's fair value procedures, apply a different value to a portfolio security than would be applied had it been priced using market quotations or by an independent fair value pricing service. Determining the fair value of securities involves the application of both subjective and objective considerations. Security values may differ depending on the methodology used to determine their values, and may differ from the last quoted sale or closing price. No assurance can be given that use of these fair value procedures will always better represent the price at which the Fund could sell the affected portfolio security. Security transactions are accounted for as of the trade date. Realized gains and losses on investments sold are recorded on the basis of identified cost for both financial statement and federal tax purposes. Fair Value Disclosure The funds adopted FASB Statement No. 157, Fair Value Measurements (FAS 157). FAS 157 establishes a single definition of fair value, a framework for measuring fair value, and expanded disclosures about fair value measurements. Various inputs are used in determining the value of the funds' investments. These inputs are classified into three broad levels: Level 1 includes quoted prices in active markets of securities identical to those of the funds. Level 2 includes: 1) quoted prices in active markets for similar securities to those of the funds; 2) quoted prices for identical or similar securities to those of the funds that trade in markets in which there are few transactions or the quoted prices are not current; 3) prices based on observable market data such as interest rates and yield curves, volatilities, bond prepayment speeds, and credit risk and; 4) prices based principally on observable market data by use of correlation techniques or other means. Level 3 includes unobservable market inputs used to fair value securities. These inputs are based on assumptions that market participants would use to price securities and may include the adviser's own assumptions. Other financial instruments are derivative instruments that are not reflected in Total Investments, such as futures, forwards, swaps, and written options contracts, which are valued based on the unrealized appreciation/depreciation of the instrument.
Elfun International Equity Fund Level 1 Level 2 Level 3 Total ----------------------------------------------------------------- Investments in Securities $ 252,904,269 $ 84,956 $ - $ 252,989,225 Other Financial Instruments $ (1,613) $ - $ - $ (1,613)
Derivatives Disclosure The Fund is subject to equity price risk, interest rate risk, and foreign currency exchange rate risk in the normal course of pursuing its investment objectives. The Fund may use futures contracts to gain exposure to, or hedge against changes in the value of equities, interest rates or foreign currencies. A futures contract represents a commitment for the future purchase or sale of an asset at a specified price on a specified date. Upon entering into such contracts, the Fund is required to deposit with the broker, either in cash or securities, an initial margin in an amount equal to a certain percentage of the contract amount. Subsequent payments (variation margin) are made or received by the Fund each day, depending on the daily fluctuations in the value of the contract, and are recorded for financial statement purposes as unrealized gains or losses by the Fund. Upon entering into such contracts, the Fund bears the risk of interest or exchange rates or securities prices moving unexpectedly, in which case, the Fund may not achieve the anticipated benefits of the futures contracts and may realize a loss. With futures contracts, there is minimal counterparty credit risk to the Fund since futures contracts are exchange traded and the exchange's clearinghouse, as counterparty to all traded futures, guarantees the futures against default. Shown below are the derivative contracts entered into by the Fund, summarized by primary risk exposure.
Asset Derivatives June 30, 2009 ---------------------------------------------------------------- Derivatives not accounted Notional Value/ for as hedging instruments Balance No. of Contracts under FASB Statement 133 Sheet Location Long/(Short) Fair Value ---------------------------------------------------------------- Liability Derivatives June 30, 2009 --------------------------------------------------------------- Derivatives not accounted Notional Value/ for as hedging instruments Balance No. of Contracts under FASB Statement 133 Sheet Location Long/(Short) Fair Value --------------------------------------------------------------- Elfun International Fund - ------------------------------------------------------------------------------------------------- Equity Contracts Payables, Net Assets - (20,190) (1,613)* Unrealized Appreciation/ (Depreciation)
* Includes cumulative appreciation/depreciation of futures contracts as reported in the Schedule of Investments. Only the current day's variation margin is reported within the Statement of Assets and Liabilities. ITEM 2. CONTROLS AND PROCEDURES. (a) The officers providing the certifications in this report in accordance with Rule 30a-3 under the Investment Company Act of 1940 have concluded, based on their evaluation of the registrant's disclosure controls and procedures (as such term is defined in such rule), that such controls and procedures are adequate and reasonably designed to achieve the purpose described in paragraph (c) of such rule. (b) There were no significant changes in the registrant's internal controls or in other factors that could significantly affect these controls subsequent to the date of their last evaluation, including any corrective actions with regard to significant deficiencies and material weaknesses. ITEM 3. EXHIBITS. Separate certifications by the registrant's principal executive officer and principal financial officer as required by Rule 30a-2(a) under the Investment Company Act of 1940, are attached: EX-99 CERT SIGNATURES Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the Registrant has duly caused this Report to be signed on its behalf by the undersigned, thereunto duly authorized. Elfun International Equity Fund By: /S/JAMES W.IRELAND James W.Ireland Trustee, President and Chief Executive Officer GE Asset Management Incorporated Date: August 26, 2009 Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated. By: /S/JAMES W.IRELAND James W.Ireland Trustee, President and Chief Executive Officer GE Asset Management Incorporated Date: August 26, 2009 By: /S/SCOTT RHODES Scott Rhodes Treasurer, Elfun Funds Date: August 26, 2009 EX-99.CERT 2 elfintercer.txt CERTIFICATION FOR ELFUN INTERNATIONAL FUND - JUNE 30, 2009 CERTIFICATIONS I, James W.Ireland, certify that: 1. I have reviewed this report on Form N-Q of the Elfun International Equity Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report; 3. Based on my knowledge, the schedules of investments included in this report fairly present in all material respects the investments of the registrant as of the end of the fiscal quarter for which the report is filed; 4. The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have: (a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared; (b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles; (c) Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report, based on such evaluation; and (d) Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during the registrant's most recent fiscal quarter that has materially affected, or is reasonably likely to materially affect, the registrant's internal control over financial reporting; and 5. The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of directors (or persons performing the equivalent functions): (a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and (b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting. Date: August 26, 2009 - ----------------------- /s/JAMES W.IRELAND James W.Ireland Trustee, President and Chief Executive Officer GE Asset Management Incorporated I, Scott Rhodes, certify that: 1. I have reviewed this report on Form N-Q of the Elfun International Equity Fund; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report; 3. Based on my knowledge, the schedules of investments included in this report fairly present in all material respects the investments of the registrant as of the end of the fiscal quarter for which the report is filed; 4. The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have: (a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared; (b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles; (c) Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report, based on such evaluation; and (d) Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during the registrant's most recent fiscal quarter that has materially affected, or is reasonably likely to materially affect, the registrant's internal control over financial reporting; and 5. The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of directors (or persons performing the equivalent functions): (a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and (b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting. Date: August 26, 2009 ----------------------- /s/SCOTT RHODES Scott Rhodes Treasurer, Elfun Funds -----END PRIVACY-ENHANCED MESSAGE-----