<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>4
<FILENAME>audit.txt
<DESCRIPTION>AUDIT LETTER
<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,
2009, 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
significant deficiencies or material weaknesses under standards
established by the Public Company Accounting Oversight Board
(United States).  In our report to you dated December 17, 2009, we reported
that we had indentified no deficiencies in the Funds internal control over
financial reporting and its operation, including controls for safeguarding
securities, that we consider to be a material weakness, as defined above,
as of October 31, 2009.

However subsequent to the filing of the Funds Form N-SAR for its fiscal
year ended October 31, 2009, 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 17, 2009, except for the 5th and 6th paragraphs as to which the
date is December 30, 2010
</TEXT>
</DOCUMENT>
