<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>accountants2004.txt
<DESCRIPTION>ACCOUNTANT LETTER
<TEXT>


Report of Independent Public Accountants

To the Board of Directors and Shareowners of NAIC Growth Fund, Inc.

We have audited the accompanying statement of assets and liabilities of
NAIC Growth Fund, Inc., including the portfolio of investments, as of
December 31, 2004 and the related statement of operations for the year
then ended, and the statement of changes in net assets and financial
highlights for each of the two years in the period then ended.  These
financial statements and financial highlights are the reponsibility of the
Fund's management.  Our responsibility is to express an opinion on
these financial statements and financial highlights based on our audit.
The financial highlights of NAIC Growth Fund, Inc. for each of the
three years in the period ended December 31, 2001 were audited by
other auditors who have ceased operations and whose most recent report
dated January 4, 2002 expressed an unqualified opinion on the financial
statements containing those financial highlights.

We conducted our audit in accordance with auditing standards generally
accepted in the United States of America.  Those standards require
that we plan and perform the audit to obtain reasonable assurance about
whether the financial statements and financial highlights are free of
material misstatement.  An audit includes examining, on a test basis,
evidence supporting the amounts and disclosures in the financial
statements.  Our procedures included confirmation of securities owned
as of December 31, 2004 by correspondence with the custodian.  An audit
also includes assessing the accounting principles used and significant
estimates made by management, as well as evaluating the overall financial
statement presentation.  We believe that our audit provides a reasonable
basis for our opinion.

In our opinion, the financial statements and financial highlights
referred to above present fairly, in all material respects, the financial
position of NAIC Growth Fund, Inc. as of December 31, 2004, the results
of its operations for the year then ended, and the statement of changes
in net assets and financial highlights for each of the two years in the
period then ended, in conformity with accounting principles generally
accepted in the United States of America.


						Plante & Moran, PLLC

January 11, 2005


</TEXT>
</DOCUMENT>
