<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>internalcontrol2005.txt
<DESCRIPTION>INTERNAL CONTROL LETTER
<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, 2005, 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 of 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, 2005.

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.


January 5, 2006

</TEXT>
</DOCUMENT>
