<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>3
<FILENAME>auditorreport.txt
<DESCRIPTION>INDEPENDENT AUDITORS REPORT
<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, 2003, 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 judgements 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, 2003.

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, 2004










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</DOCUMENT>
