<DOCUMENT>
<TYPE>EX-99
<SEQUENCE>2
<FILENAME>nsar-aaletter.txt
<DESCRIPTION>INDEPENDENT AUDITORS REPORT
<TEXT>

Independent Auditors Report
To the Board of Directors of
NAIC Growth Fund, Inc.:

In planning and performing our audit of the financial statements
of NAIC Growth Fund, Inc. for the year ended December 31, 2000,
we considered its internal control,including control activities
for safeguarding securities, in order to determine our auditing
procedures for the purpose of expressing our opinion on the
financial statements and to comply with the requirements of Form
N-SAR, not to provide assurance on internal control. The
management of NAIC Growth Fund, Inc. is responsible for
establishing and maintaining internal control.  In fulfilling
this responsibility, estimates and judgments by management are
required to assessthe expected benefits and related costs of
controls.  Generally, controls that are relevant to an audit
pertain to the entitys objective of preparing financial
statements for external purposes that are fairly presented in
conformity with generally accepted accounting principles. Those
controls include the safeguarding of assets against unauthorized
acquisition, use, or disposition.

Because of inherent limitations in internal control, error or
fraud may occur andnot be detected.  Also, projection of any
evaluation of internal control to futureperiods is subject to
the risk that it may become inadequate because of changes
in conditions or that the effectiveness of the design and
operation may deteriorate.Our consideration of internal control
would not necessarily disclose all matters in internal control
that might be material weaknesses under standards established
by the American Institute of Certified Public Accountants. A
material weakness is acondition in which the design or operation
of one or more of the internal control components does not reduce
to a relatively low level the risk that misstatements caused by
error or fraud in amounts that would be material in relation to
the financial statements being audited may occur and not be
detected within a timely period by employees in the normal course
of performing their assigned functions.  However, we noted no
matters involving internal control and its operation, including
controls for safeguarding securities, that we consider to be
materialweaknesses as defined above as of December 31, 2000.

This report is intended solely for the information and use of
management and the Audit Committee of NAIC Growth Fund, Inc. and
the Securities and Exchange Commissionand is not intended to be
and should not be used by anyone other than these
specified parties.


Detroit, Michigan
    January 5, 2001





</TEXT>
</DOCUMENT>
