<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>audit.txt
<DESCRIPTION>AUDIT
<TEXT>
Report of Independent Registered Public Accounting Firm

To the Shareholders and Board of Directors of
The China Fund, Inc.:

In planning and performing our audit of the financial statements of The
China Fund, Inc., (the Fund), as of and for the year ended October 31,
2010 and in accordance with the standards of the Public Company Accounting
Oversight Board (United States), we considered the Funds 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 Funds internal control over financial
reporting.  Accordingly, we express no such opinion.

The 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 companys
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 companys 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 company; and (3) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of a companys 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 the 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 companys annual or interim financial
statements will not be prevented or detected on a timely basis.

Our consideration of the Funds 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 the
following deficiencies involving the control environment, and control
procedures and their operation that we consider to be material weaknesses
as defined above. These deficiencies were considered in determining the
nature, timing and extent of the procedures to be performed in our audit
of the financial statements of the Fund for the year ended October 31,
2010, and this report does not affect our report on the financial
statements of the Fund dated December 30, 2010.

Management has identified certain weaknesses in the operation of the Funds
controls in respect of the Funds direct investment portfolio, which
generally consists of investments which are not publicly traded
(direct investments). Specifically, those controls did not operate to
prevent the Fund from entering into a transaction in April 2009, being the
purchase of Ugent Holdings Ltd. 12% bond (Ugent), a transaction that
involved certain related parties.  Further, the controls did not operate
with sufficient effectiveness to allow management to detect this issue on a
timely basis.  The issue was identified in October 2010.  Promptly upon
identification of the issue, the Funds Board of Directors instructed Martin
Currie Inc. (the Direct Investment Manager) to suspend any further direct
investment activity, pending the completion of an investigation into the
circumstances of the transaction and the implementation of enhancements to
the Funds controls over direct investments. In addition, a review by the
Direct Investment Manager has confirmed that there were no similar
occurrences in connection with any of the Funds other direct investments.
Further, the Direct Investment Manager has arranged for the Fund to be
indemnified against any loss arising from the sale of Ugent to an unrelated
third party or, if no sale of the Ugent takes place prior to Ugents
maturity date, to be reimbursed for the cost of its investment, less any
interest or other income received by April 2012.

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


							ERNST & YOUNG LLP

Boston, Massachusetts
December 30, 2010
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</DOCUMENT>
