SECURITIES AND EXCHANGE COMMISSION
Washington D.C. 20549

FORM N-17f-2

Certificate of Accounting of Securities and Similar
Investments in the Custody of
Management Investment Companies

Pursuant to Rule 17f-2 [17 CFR 270.17f-2]

1.    Investment Company Act File Number:    Date examination completed:

               811-3218                         November 18, 2005

2. State identification Number:

AL       AK       AZ       AR       CA      CO
CT       DE       DC       FL       GA      HI
ID       IL       IN       IA       KS      KY
LA       ME       MD       MA       MI      MN
MS       MO       MT       NE       NV      NH
NJ       NM       NY       NC       ND      OH
OK       OR       PA       RI       SC      SD
TN       TX       UT       VT       VA      WA
WV       WI       WY       PUERTO RICO

Other  (specify):

3. Exact name of investment company as specified in registration statement:

     AXP Variable Portfolio - Investment Series, Inc.

4. Address of principal executive office (number,street,city,state,zip code):

     50606 Ameriprise Financial Center, Minneapolis, MN 55474

          THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT


             Report of Independent Registered Public Accounting Firm


To the Board of Directors of
AXP Variable Portfolio - Investment Series, Inc.:

We have examined management's assertion, included in the accompanying Management
Statement Regarding Compliance with Certain Provisions of the Investment Company
Act of 1940, that RiverSource Variable Portfolio - Mid Cap Value Fund of AXP
Variable Portfolio - Investment Series, Inc. (the Fund) complied with the
provisions of subsection (b) and (c) of Rule 17f-2 under the Investment Company
Act of 1940 as of August 31, 2005 and during the period from July 31, 2005 (the
date of our last examination) through August 31, 2005. Management is responsible
for the Fund's compliance with those provisions. Our responsibility is to
express an opinion on management's assertion about the Fund's compliance based
on our examination.

Our examination was made in accordance with standards established by the Public
Company Accounting Oversight Board (United States) 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 August 31, 2005 and during the period July 31, 2005 through
August 31, 2005, with respect to securities transactions:

o    Count and inspection of all securities located in the vault, if any, of
     Ameriprise Trust Company, the Custodian;

o    Confirmation of all securities, if any, held by institutions in book entry
     form (Wells Fargo Bank Minnesota, N.A., The Bank of New York, and The
     Depository Trust Company);

o    Confirmation or examination of underlying documentation of all securities
     purchased but not received, hypothecated, pledged, placed in escrow, or out
     for transfer with brokers, pledges and/or transfer agents;

o    Reconciliation of all such securities to the books and records of the Fund
     and the Custodian; and

o    Test of selected security transactions since the date of our last report.


We believe that our examination provides a reasonable basis for our opinion. Our
examination does not provide a legal determination on the Fund's compliance with
the specified requirements.



In our opinion, management's assertion that the Fund was in compliance with the
above mentioned provisions of Rule 17f-2 of the Investment Company Act of 1940
as of August 31, 2005 and during the period from July 31, 2005 through August
31, 2005 is fairly stated in all material respects.

This report is intended solely for the information and use of management of the
Fund and the Securities and Exchange Commission and should not be used for any
other purpose and is not intended to be and should not be used by anyone other
than these specified parties.




/s/ KPMG LLP
- ----------------
    KPMG LLP
    Minneapolis, MN
    November 18, 2005


             Management Statement Regarding Compliance With Certain
                Provisions of the Investment Company Act of 1940



     We, as members of management of RiverSource Variable Portfolio - Mid Cap
     Value Fund of AXP Variable Portfolio - Investment Series, Inc. (the Fund)
     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 effective internal controls
     over compliance with those requirements. We have performed an evaluation of
     the Fund's compliance with the requirements of subsections (b) and (c) of
     Rule 17f-2 as of August 31, 2005 and from July 31, 2005 through August 31,
     2005.

     Based on this evaluation, we assert that the Fund was in compliance with
     the requirements of subsections (b) and (c) of Rule 17f-2 of the Investment
     Company Act of 1940 as of August 31, 2005 and from July 31, 2005 through
     August 31, 2005, with respect to securities reflected in the investment
     account of the Fund.



     AMERIPRISE FINANCIAL, INC.



     By: /s/ Jeffrey P. Fox
         ------------------------
             Jeffrey P. Fox, Vice President-Investment Accounting