-----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, EEkjnaKRn3fTi9YjKsrKlmCXzdaF6EV1VwwLWPfWQ9sHNfExeAMGTLN3kK4fHK+y 6g0MfJaxZSclOYmykV0ZvA== 0000950137-07-018044.txt : 20071130 0000950137-07-018044.hdr.sgml : 20071130 20071130111950 ACCESSION NUMBER: 0000950137-07-018044 CONFORMED SUBMISSION TYPE: 40-17F2 PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20071130 DATE AS OF CHANGE: 20071130 EFFECTIVENESS DATE: 20071130 SUBJECT COMPANY: COMPANY DATA: COMPANY CONFORMED NAME: RIVERSOURCE VARIABLE PORTFOLIO INVESTMENT SERIES, INC. CENTRAL INDEX KEY: 0000353968 IRS NUMBER: 411409539 STATE OF INCORPORATION: MN FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: 40-17F2 SEC ACT: 1940 Act SEC FILE NUMBER: 811-03218 FILM NUMBER: 071276779 BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 6126714321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: AXP VARIABLE PORTFOLIO INVESTMENT SERIES INC DATE OF NAME CHANGE: 19991126 FORMER COMPANY: FORMER CONFORMED NAME: IDS LIFE INVESTMENT SERIES INC DATE OF NAME CHANGE: 19981102 FORMER COMPANY: FORMER CONFORMED NAME: IDS LIFE CAPITAL RESOURCE FUND INC DATE OF NAME CHANGE: 19920703 FILED BY: COMPANY DATA: COMPANY CONFORMED NAME: RIVERSOURCE VARIABLE PORTFOLIO INVESTMENT SERIES, INC. CENTRAL INDEX KEY: 0000353968 STANDARD INDUSTRIAL CLASSIFICATION: UNKNOWN SIC - 0000 [0000] IRS NUMBER: 411409539 STATE OF INCORPORATION: MN FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: 40-17F2 BUSINESS ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 BUSINESS PHONE: 6126714321 MAIL ADDRESS: STREET 1: 50606 AMERIPRISE FINANCIAL CENTER STREET 2: H27/5228 CITY: MINNEAPOLIS STATE: MN ZIP: 55474 FORMER COMPANY: FORMER CONFORMED NAME: AXP VARIABLE PORTFOLIO INVESTMENT SERIES INC DATE OF NAME CHANGE: 19991126 FORMER COMPANY: FORMER CONFORMED NAME: IDS LIFE INVESTMENT SERIES INC DATE OF NAME CHANGE: 19981102 FORMER COMPANY: FORMER CONFORMED NAME: IDS LIFE CAPITAL RESOURCE FUND INC DATE OF NAME CHANGE: 19920703 40-17F2 1 c21984ie40v17f2.txt 40-17F2 ------------------------ OMB APPROVAL ------------------------ OMB Number: 3235-0360 Expires: July 31, 2009 Estimated average burden hours per response...2.1 ------------------------ UNITED STATES 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 26, 2007 - -------------------------------------------------------------------------------- 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: RiverSource Variable Portfolio Investment Series, Inc. - -------------------------------------------------------------------------------- 4. Address of principal executive office (number, street, city, state, zip code): 50606 Ameriprise Financial Center, Minneapolis, MN 55474 - -------------------------------------------------------------------------------- INSTRUCTIONS This Form must be completed by investment companies that have custody of securities or similar investments. INVESTMENT COMPANY 1. All items must be completed by the investment company. 2. Give this Form to the independent public accountant who, in compliance with Rule 17f-2 under the Act and applicable state law, examines securities and similar investments in the custody of the investment company. ACCOUNTANT 3. Submit this Form to the Securities and Exchange Commission and appropriate state securities administrators when filing the certificate of accounting required by Rule 17f-2 under the Act and applicable state law. File the original and one copy with the Securities and Exchange Commission's principal office in Washington, D.C., one copy with the regional office for the region in which the investment company's principal business operations are conducted, and one copy with the appropriate state administrator(s), if applicable. THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT Report of Independent Registered Public Accounting Firm To the Board of Directors of RiverSource Funds 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 the following Funds: RiverSource Mid Cap Growth Fund; RiverSource Portfolio Builder Conservative Fund; RiverSource Global Bond Fund; RiverSource International Opportunity Fund; RiverSource Global Technology Fund; RiverSource Global Equity Fund; RiverSource Emerging Markets Fund; RiverSource Small Company Index Fund; RiverSource Diversified Equity Income Fund; RiverSource European Equity Fund; RiverSource S&P 500 Index Fund; RiverSource Portfolio Builder Moderate Fund; RiverSource Portfolio Builder Moderate Aggressive Fund; RiverSource International Select Value Fund; RiverSource Portfolio Builder Aggressive Fund; RiverSource Portfolio Builder Total Equity Fund; RiverSource Portfolio Builder Moderate Conservative Fund; RiverSource Absolute Return Currency and Income Fund; RiverSource Emerging Markets Bond Fund; RiverSource VP-Diversified Bond Fund; RiverSource VP-Cash Management Fund; RiverSource VP-International Opportunity Fund; RiverSource VP-Global Bond Fund; RiverSource VP-High Yield Bond Fund; RiverSource VP-Growth Fund; RiverSource VP-Diversified Equity Income Fund; RiverSource VP-Short Duration U.S. Government Fund; RiverSource VP-S&P 500 Index Fund; RiverSource VP-Emerging Markets Fund; RiverSource VP-Mid Cap Growth Fund; RiverSource VP-Core Bond Fund; RiverSource VP-Large Cap Value Fund; RiverSource VP-Income Opportunities Fund; RiverSource VP-Global Inflation Protected Securities Fund; RiverSource VP -Core Equity Fund; RiverSource VP-Mid Cap Value Fund; RiverSource VP-Fundamental Value Fund; RiverSource Balanced Fund; RiverSource Strategic Allocation Fund; RiverSource International Small Cap Fund; RiverSource International Equity Fund; RiverSource International Aggressive Growth Fund; RiverSource VP-Large Cap Equity Fund; RiverSource VP-Small Cap Advantage Fund; RiverSource VP-Small Cap Value Fund; RiverSource VP-Select Value Fund; RiverSource Disciplined Large Cap Growth Fund; RiverSource Strategic Income Allocation Fund; of the RiverSource Funds (referred to collectively as the Funds) complied with the requirements of subsections (b) and (c) of rule 17f-2 of the Investment Company Act of 1940 (the Act) as of August 31, 2007. Management is responsible for the Funds' compliance with those requirements. Our responsibility is to express an opinion on management's assertion about the Funds' compliance based on our examination. Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) 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 August 31, 2007, and with respect to agreement of security purchases and sales, for the period from September 1, 2006 through August 31, 2007: - - Count and inspection of all securities located in the vault of Ameriprise Trust Company (the Custodian) in Minneapolis, Minnesota, without prior notice to management; - - Confirmation of all securities held by institutions in book entry form (Wells Fargo and Depository Trust Company); - - Confirmation of all securities hypothecated, pledged, placed in escrow, or out for transfer with brokers, pledgees, or transfer agents; - - Review of reconciliation of all such securities to the books and records of the Funds and the Custodian; - - Agreement of twenty-five security purchases, security sales or maturities from the books and records of the Funds to broker confirmations. We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Funds' compliance with specified requirements. In our opinion, management's assertion that the Funds complied with the requirements of subsections (b) and (c) of rule 17f-2 of the Act as of August 31, 2007, with respect to securities reflected in the investment accounts of the Funds is fairly stated, in all material respects. This report is intended solely for the information and use of management and the Board of Directors of the Funds and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties. /s/ Ernst & Young LLP Minneapolis, Minnesota November 26, 2007 Management Statement Regarding Compliance With Certain Provisions of the Investment Company Act of 1940 November 26, 2007 I, as a member of management of the RiverSource Mid Cap Growth Fund, RiverSource Portfolio Builder Conservative Fund, RiverSource Global Bond Fund, RiverSource International Opportunity Fund, RiverSource Global Technology Fund, RiverSource Global Equity Fund, RiverSource Emerging Markets Fund, RiverSource Small Company Index Fund, RiverSource Diversified Equity Income Fund, RiverSource European Equity Fund, RiverSource S&P 500 Index Fund, RiverSource Portfolio Builder Moderate Fund, RiverSource Portfolio Builder Moderate Aggressive Fund, RiverSource International Select Value Fund, RiverSource Portfolio Builder Aggressive Fund, RiverSource Portfolio Builder Total Equity Fund, RiverSource Portfolio Builder Moderate Conservative Fund, RiverSource Absolute Return Currency and Income Fund, RiverSource Emerging Markets Bond Fund, RiverSource VP-Diversified Bond Fund, RiverSource VP-Cash Management Fund, RiverSource VP-International Opportunity Fund, RiverSource VP-Global Bond Fund, RiverSource VP-High Yield Bond Fund, RiverSource VP-Growth Fund, RiverSource VP-Diversified Equity Income Fund, RiverSource VP-Short Duration U.S. Government Fund, RiverSource VP-S&P 500 Index Fund, RiverSource VP-Emerging Markets Fund, RiverSource VP-Mid Cap Growth Fund, RiverSource VP-Core Bond Fund, RiverSource VP-Large Cap Value Fund, RiverSource VP-Income Opportunities Fund, RiverSource VP-Global Inflation Protected Securities Fund, RiverSource VP-Core Equity Fund, RiverSource VP-Mid Cap Value Fund, RiverSource VP-Fundamental Value Fund, RiverSource Balanced Fund, RiverSource Strategic Allocation Fund, RiverSource International Small Cap Fund, RiverSource International Equity Fund, RiverSource International Aggressive Growth Fund, RiverSource VP-Large Cap Equity Fund, RiverSource VP-Small Cap Advantage Fund, RiverSource VP-Small Cap Value Fund, RiverSource Select Value Fund, RiverSource Disciplined Large Cap Growth Fund, and RiverSource Strategic Income Allocation Fund (referred to collectively as the Funds), am 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. I am also responsible for establishing and maintaining effective internal controls over compliance with those requirements. I have performed an evaluation of the Funds' compliance with the requirements of subsections (b) and (c) of rule 17f-2 as of August 31, 2007, and from the date of the last examination of each fund through August 31, 2007. Based on this evaluation, I assert that the 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 August 31, 2007, and from the date of the last examination of each fund through August 31, 2007, with respect to securities reflected in the investment accounts of the Funds. By: /s/ Jeffrey P. Fox --------------------------------- Jeffrey P. Fox Treasurer RiverSource Funds -----END PRIVACY-ENHANCED MESSAGE-----