CORRESP 1 filename1.htm

July 15, 2005
Laura Hatch and Tony Burak
Securities and Exchange Commission
Division of Investment Management
Office of Disclosure
Mail Stop 0505
Washington, DC 20549
RE:	T. Rowe Price Funds
	October 31, 2004 and December 31, 2004 Annual Reports
Dear Ms. Hatch and Mr. Burak:
Following are responses to the comments/questions we discussed on May 13, 2005, related
to the October 31, 2004 and December 31, 2004 annual reports for the T. Rowe Price
funds.

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 the Statement 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 the Statement of Assets and
	Liabilities the 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 the Statement 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 the Statement of
	Operations as a decrease in total expenses.
	Management Response: The Statement of Operations of 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 the Statement of Operations and 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 the Growth 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 $10,000 performance 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
	the Growth of $10,000 performance 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 the Statement of Assets and Liabilities of New
	Asia Fund does not agree to the total value of investments in affiliated companies
	presented in the affiliate schedule following the Portfolio of Investments.
	Management Response: The value of the three affiliated companies presented in the
	affiliate schedule following the Portfolio of Investments was misclassified as
	unaffiliated on the Statement 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 the Statement of Assets and Liabilities agrees
	with the total value of affiliated companies held at period-end shown in the affiliate
	schedule.

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.
Sincerely,
Neil Kotras
Investment Treasury
cc: Joe Carrier
Forrest Foss
Cathy Mathews