<DOCUMENT>
<TYPE>EX-99.77Q2
<SEQUENCE>3
<FILENAME>d73956_ex99-77q2.txt
<DESCRIPTION>ITEM 405
<TEXT>

                             NAIC GROWTH FUND, INC.

Exhibit 99.77Q2 ITEM 405

Section 16(a) Beneficial Ownership Reporting Compliance

      Directors  and  officers  of the Fund and  certain of its  affiliates  and
beneficial  owners of more than 10% of the  Common  Stock are  required  to file
initial  reports of ownership  and reports of changes in ownership of the Common
Stock  pursuant to Section  16(a) of the  Securities  Exchange  Act of 1934,  as
amended.  The  Fund  has  reviewed  such  reports  received  by it  and  written
representations of such persons who are known by the Fund, and based solely upon
such review,  the Fund believes that during the year ended December 31, 2007 all
such reports were timely filed except with respect to one filing with respect to
two  transactions  by the President of the Fund,  and one filing with respect to
one transaction in 2007 and the initial filing by the Chief  Compliance  Officer
of the Fund.

</TEXT>
</DOCUMENT>
