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| 1. | Manager Commentary(N-1A, Item 21(d)(1)) |
| | The hypothetical expense example presented in the shareholder reports of the variable |
| | annuity funds should state that the example does not include any fees or expenses |
| | imposed at the contract level. |
| |
| | Management Response:Beginning with the June 30, 2005 reporting cycle, the |
| | hypothetical expense example presented in shareholder reports of T. Rowe Price |
| | variable annuity funds will include language stating that, “Figures do not reflect fees at |
| | the insurance product or contract level; if those fees were included, expenses would be |
| | higher.” |
| |
| 2. | Statement of Assets and Liabilities(Reg. S-X, Rule 6-04(11)) |
| | Disclose separately on theStatement of Assets and Liabilities“deposits for securities |
| | loaned” as prescribed by S-X 6-04(11). |
| |
| | Management Response:Beginning with the February 28, 2005 reporting cycle, all T. |
| | Rowe Price funds began to present separately on the face of theStatement of Assets and |
| | Liabilitiesthe liability to return securities lending collateral. Previously, such amounts |
| | had been presented separately only if the balance exceeded 5% of the fund’s net assets. |
| | Additionally, the footnotes to the financial statements state the total value of securities |
| | loaned and the nature of the collateral received. |
| |
| 3. | Statement of Operations(Reg. S-X, Rule 6-07) |
| | On theStatement of Operations, state separately dividend and interest income from |
| | investments in affiliated companies. |
| | Management Response:Beginning with the June 30, 2005 reporting cycle, T. Rowe |
| | Price funds will disclose dividend and interest income from investments in affiliated |
| | companies separately in accordance with Regulation S-X, Rule 6-07. |
| |
| 4. | Statement of Operations (Reg. S-X, Rule 6-07) |
| | The manager of the Personal Strategy Balanced Portfolio charges an all-inclusive |
| | management and administrative fee, which it reduced by $38,000 during the year ended |
| | December 31, 2004 related to the fund’s investment in T. Rowe Price Institutional High |
| | Yield Fund. This fee reduction should be presented separately on theStatement of |
| | Operationsas a decrease in total expenses. |
| |
| | Management Response:TheStatement of Operationsof the Personal Strategy |
| | Balanced Portfolio erroneously reflected a net presentation of the fund’s management |
| | fee. It is the policy of T. Rowe Price funds that the management fee should be |
| | presented gross on theStatement of Operationsand any contractual management fee |
| | reduction should be presented separately as a reduction to arrive at total expenses. |
| | Total expenses were reported accurately and the expense ratios in the financial |
| | highlights were calculated and presented correctly. |
| |
| 5. | Manager Commentary |
| | The Average Annual Compound Total Return Since Inception for the MSCI EAFE |
| | Index presented in the annual report of the International Growth & Income Fund does |
| | not agree to the return recalculated using the plot points in theGrowth of $10,000 |
| | performance comparison chart. |
| |
| | Management Response:The inception date of the International Growth & Income |
| | Fund is December 21, 1998. It is the policy of T. Rowe Price funds that since- |
| | inception performance information for a fund’s benchmark should be presented from |
| | the date of fund inception, when such information is available for the benchmark. The |
| | Average Annual Compound Total Return Since Inception for the MSCI EAFE Index |
| | presented in the fund’s annual report was calculated for the period from December 21, |
| | 1998 (inception date of the fund) to October 31, 2004; however, the tickmark |
| | accompanying the performance calculation erroneously stated, “. for the period |
| | 12/31/98 to 10/31/04.” We have enhanced our financial statement review process to |
| | include a procedure to verify that the periods disclosed in the tickmark explanations for |
| | since-inception benchmark data presented in the annual report are appropriate. |
| |
| 6. | Manager Commentary |
| | The Average Annual 5-Year and 10-Year Compound Total Returns for the Citigroup |
| | Non-U.S. Extended Market Index presented in the T. Rowe Price International |
| | Discovery Fund do not agree to the returns recalculated using the plot points in the |
| | Growth of $10,000performance comparison chart. |
| |
| | Management Response:The Average Annual 5-Year and 10-Year Compound Total |
| | Returns presented for the Citigroup Non-U.S. Extended Market Index presented in the |
| | International Discovery Fund annual report were accurate; however, the plot points for |
| | theGrowth of $10,000performance comparison chart as of October, 2002, October, |
| | 2003 and October, 2004 were misstated due to inaccurate data points in our internal |
| | statistical reporting database. We have corrected the data in our internal statistical |
| | reporting database and enhanced our period-end review process to include a procedure |
| | to verify that all performance data contained in our internal statistical reporting |
| | database agrees to the performance data provided by the benchmark organization. |
| |
| 7. | Statement of Assets and Liabilities |
| | The value of affiliated companies in theStatement of Assets and Liabilitiesof New |
| | Asia Fund does not agree to the total value of investments in affiliated companies |
| | presented in the affiliate schedule following thePortfolio of Investments. |
| |
| | Management Response:The value of the three affiliated companies presented in the |
| | affiliate schedule following thePortfolio of Investmentswas misclassified as |
| | unaffiliated on theStatement of Assets and Liabilities. We have enhanced our financial |
| | statement review checklist to include a procedure to verify that the value of investments |
| | in affiliated companies as reflected on theStatement of Assets and Liabilitiesagrees |
| | with the total value of affiliated companies held at period-end shown in the affiliate |
| | schedule. |
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| In connection with responding to your comments, T. Rowe Price acknowledges that: |
| |
| • | the fund is responsible for the adequacy and accuracy of the disclosure in the filings; |
| • | staff comments or changes to disclosure in response to staff comments in the filings |
| | reviewed by the staff do not foreclose the Commission from taking any action with |
| | respect to the filing; and |
| • | the fund may not assert staff comments as a defense in any proceedings initiated by |
| | the Commission or any person under the federal securities laws of the United States. |
| |
| If you have any additional questions after reviewing or would like to discuss any of the |
| responses further, I can be reached at (410) 345-2014 or via email at |
| neil_kotras@troweprice.com. |
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| Sincerely, |
| |
| |
| Neil Kotras |
| Investment Treasury |
|
| cc: Joe Carrier |
| Forrest Foss |
| Cathy Mathews |
