<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>internalcontrol2006.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, 2006, 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, 2006.

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 16, 2007

</TEXT>
</DOCUMENT>
