<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>item77b.txt
<DESCRIPTION>AUDIT LETTER
<TEXT>
Report of Independent Registered Public Accounting Firm
To the Board of Directors and Shareholders of
Aberdeen Asia-Pacific Income Fund, Inc.:

In planning and performing our audits of the financial statements of the
Aberdeen Asia -Pacific Income Fund, Inc. (the "Fund") as of and for the year
ended October 31, 2010, in accordance with the standards of the Public Company
Accounting Oversight Board (United States), we considered the Fund's internal
control over financial reporting, including controls over safeguarding
securities, as a basis for designing our auditing procedures
for the purpose of expressing our opinion on the financial statements
and to comply with the requirements of Form N-SAR, but not for the purpose of
expressing an opinion on the effectiveness of the Fund's internal control over
financial reporting. Accordingly, we express no such opinion.

Management of the Fund is responsible for establishing and maintaining
effective internal control over financial reporting. In fulfilling this
responsibility, estimates and judgments by management are required to
assess the expected benefits and related costs of controls. A company's
internal control over financial reporting is a process designed
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. A company's
internal control over financial reporting includes those policies and
procedures that (1) pertain to the maintenance of records that,
in reasonable detail, accurately and fairly reflect the transactions and
dispositions of the assets of the company; (2) provide reasonable assurance
that transactions are recorded as necessary to permit preparation of financial
statements in accordance with generally accepted accounting principles, and
that receipts and expenditures of the company are being made only in
accordance with authorizations of management and directors of the Fund;
and (3) provide reasonable assurance regarding prevention or timely
detection of unauthorized acquisition, use, or disposition of the company's
assets that could have a material effect on the financial statements.

Because of its inherent limitations, internal control over financial
reporting may not prevent or detect misstatements. Also, projections of
any evaluation of effectiveness to future periods are subject to the risk
that controls may become inadequate because of
changes in conditions, or that the degree of compliance with policies or
procedures may deteriorate.

A deficiency in internal control over financial reporting exists when the
design or operation of a control does not allow management or employees,
in the normal course of performing their assigned functions, to prevent or
detect misstatements on a timely basis. A material weakness is a deficiency,
or a combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a material
misstatement of the Fund's annual or interim financial statements will not be
prevented or detected on a timely basis.

Our consideration of the Fund's internal control over financial reporting
was for the limited purpose described in the first paragraph and would not
necessarily disclose all deficiencies in internal control that might be
material weaknesses under standards established by the Public Company
Accounting Oversight Board (United States). However,
we noted no deficiencies in the Fund's internal control over financial
reporting and its operations, including controls over safeguarding securities
that we consider to be a material weakness as defined above as of
October 31, 2010.

This report is intended solely for the information and use of management
and the Board of Directors of Aberdeen Asia-Pacific Income Fund, Inc.
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/ KPMG LLP



December 28, 2010
Philadelphia, PA


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</DOCUMENT>
