REPORT OF INDEPENDENT REGISTERED PUBLIC
ACCOUNTING FIRM


To the Board of Trustees and the Shareholders of
Dunham Funds


In planning and performing our audits of the financial
statements of Dunham Corporate/Government Bond
Fund Dunham Floating Rate Bond Fund Dunham High-
Yield Bond Fund Dunham International Opportunity
Bond Fund Dunham Large Cap Value Fund Dunham
Small Cap Value Fund Dunham Focused Large Cap
Growth Fund Dunham Small Cap Growth Fund Dunham
Emerging Markets Stock Fund Dunham International
Stock Fund Dunham Dynamic Macro Fund Dunham
LongShort Credit Fund Dunham Monthly Distribution
Fund and Dunham Real Estate Stock Fund each a
series of shares of beneficial interest in Dunham Funds
(the Funds) as of October 31 2022 and for the year then
ended in accordance with the standards of the Public
Company Accounting Oversight Board (United States)
(PCAOB) we considered the Funds internal control over
financial reporting including controls over safeguarding
securities as a basis for designing our auditing
procedures for the purpose of expressing our opinion on
the financial statements and to comply with the
requirements of Form N-CEN but not for the purpose of
expressing an opinion on the effectiveness of the Funds
internal control over financial reporting.  Accordingly we
express no such opinion.

The management of the Funds is responsible for
establishing and maintaining effective internal control
over financial reporting.  In fulfilling this responsibility
estimates and judgments by management are required
to assess the expected benefits and related costs of
controls.  A funds internal control over financial reporting
is a process designed to provide reasonable assurance
regarding the reliability of financial reporting and the
preparation of financial statements for external purposes
in accordance with accounting principles generally
accepted in the United States of America (GAAP).  A
funds internal control over financial reporting includes
those policies and procedures that (1) pertain to the
maintenance of records that in reasonable detail
accurately and fairly reflect the transactions and
dispositions of the assets of the fund (2) provide
reasonable assurance that transactions are recorded as
necessary to permit preparation of the financial
statements in accordance with GAAP and that receipts
and expenditures of the fund are being made only in
accordance with authorizations of management and
trustees of the fund; and (3) provide reasonable
assurance regarding prevention or timely detection of
unauthorized acquisition use or disposition of a funds
assets that could have a material effect on the financial
statements.

Because of inherent limitations internal control over
financial reporting may not prevent or detect
misstatements.  Also projections of any evaluation of
effectiveness to future periods are subject to the risk that
controls may become inadequate because of changes in
conditions or that the degree of compliance with the
policies or procedures may deteriorate.

A deficiency in internal control over financial reporting
exists when the design or operation of a control does not
allow management or employees in the normal course of
performing their assigned functions to prevent or detect
misstatements on a timely basis.  A material weakness
is a deficiency or combination of deficiencies in internal
control over financial reporting such that there is a
reasonable possibility that a material misstatement of the
Funds annual or interim financial statements will not be
prevented or detected on a timely basis.




Our consideration of the Funds internal control over
financial reporting was for the limited purpose described
in the first paragraph and would not necessarily disclose
all deficiencies in internal control that might be material
weaknesses under standards established by the
PCAOB.  However we noted no deficiencies in the
Funds internal control over financial reporting and its
operation including controls over safeguarding securities
that we consider to be a material weakness as defined
above as of October 31 2022.

This report is intended solely for the information and use
of management and the Board of Trustees of Dunham
Funds and the Securities and Exchange Commission
and is not intended to be and should not be used by
anyone other than these specified parties.



/s/BBD LLP


Philadelphia Pennsylvania
December 30 2022