<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>internalletter-2002.txt
<DESCRIPTION>INTERNAL CONTROL LETTER AUDITORS
<TEXT>
Independent Auditor's Report on Internal Control


To the Audit Committee of
     the Board of Directors
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, 2002, 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 assess the expected benefits and related costs of
controls.  Generally, controls that are relevant to an audit pertain to
the entity's objective of preparing financial statements for external
purposes that are fairly presented in conformity with accounting
principles generally accepted in the United States of America.
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 and not be detected.  Also, projection of any evaluation
of internal control to future periods 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 a condition 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 material weaknesses as defined above as of
December 31, 2002.

This report is intended solely for the information and use of
management and the Audit Committee of the Board of Directors of
NAIC Growth 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.


Plante & Moran, PLLC
   January 7, 2003




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