<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>auditorletter2006.txt
<DESCRIPTION>AUDITOR LETTER
<TEXT>


Report of Independent Registered Accounting Firm

To the Board of Directors and Shareowners
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, 2006 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 responsibility of the Fund's
management. Our responsibility is to express an
opinion on these financial statements and financial
highlights based on our audit.
     We conducted our audit in accordance with the
standards of the Public Company Accounting Oversight
Board (United States).  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,
2006 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, 2006, the
results of its operations for the year then ended, and
the statement of changes in net assets  for the two
years in the period then ended and the financial
highlights for each of the five years in the period then
ended, in conformity with accounting principles
generally accepted in the United States of America.


			Plante & Moran, PLLC

January 16, 2007




</TEXT>
</DOCUMENT>
