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

To the Board of Directors and Shareholders
of PCM Fund, Inc.

In planning and performing our audit of the financial statements of PCM Fund,
Inc. ("the Fund") as of and for the year ended December 31, 2009, 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 do not express an opinion
on the effectiveness of the Fund's internal control over financial reporting.
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 fund'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 fund'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 fund;
(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
fund 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 a fund'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 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 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 over financial
reporting 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 operation, including controls over safeguarding securities, that we
consider to be material weaknesses as defined above as of December 31, 2009.
This report is intended solely for the information and use of management and
the Board of Directors of PCM 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.


PricewaterhouseCoopers LLP
Kansas City, Missouri
February 22, 2010

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</DOCUMENT>
