<DOCUMENT>
<TYPE>EX-99
<SEQUENCE>3
<FILENAME>nsarsemiattachment2002.txt
<DESCRIPTION>CHANGE IN ACCOUNTANTS
<TEXT>


CHANGE IN ACCOUNTANTS
At a meeting held on May 9, 2002, the Board of Directors of NAIC
Growth Fund, Inc., at the recommendation of its Audit Committee,
approved the engagement of Plante & Moran, LLP as its independent
auditors for the fiscal year ending December 31, 2002 to replace the firm
of Arthur Andersen LLP ("Andersen"), who were dismissed as the
independent auditors of the Fund effective May 9, 2002.

The reports of Andersen on the Fund's financial statements for the past
two years did not contain an adverse opinion or a disclaimer of opinion
and were not qualified or modified as to uncertainty, audit scope, or
accounting principles.

In connection with the audits of the Fund's financial statements for the
fiscal years ended December 31, 2001 and 2000 and in the subsequent
interim period, there were no disagreements with Andersen on any
matter of accounting principles or practices, financial statement
disclosure, or auditing scope or procedure, which, if not resolved to the
satisfaction of Andersen, would have caused it to make a reference to the
matter in its report.  In addition, there were no reportable events as
definedin Item 304(a)(1)(v) of Regulation S-K.

The Fund has requested Andersen to furnish it a letter addressed to the
Securities and Exchange Commission stating whether it agrees with the
above statements.  Andersen has informed the Fund that it is no longer
furnishing such letters.

The Fund has not had any discussions nor received any written opinion
or oral advice from Plante & Moran, LLP during the two most recent
fiscal years and in the subsequent interim period with respect to either
the application of accounting principles to a specified transaction, either
completed or proposed, or as to the type of audit opinion that might be
rendered on the Fund's financial statements.


</TEXT>
</DOCUMENT>
