EX-99.B-77B


                                   IVY FUNDS

SUB-ITEM 77B:  Accountant's report on internal control
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REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Trustees and Shareholders of Ivy Funds:

In planning and performing our audits of the financial statements of Ivy Funds
(the "Company") (including the Balanced Fund, Bond Fund, Cash Reserves Fund,
Cundill Global Value Fund, Dividend Income Fund, European Opportunities Fund,
Global Natural Resources Fund, International Fund, International Balanced Fund,
International Value Fund, Mortgage Securities Fund, Pacific Opportunities Fund,
Real Estate Securities Fund, Small Cap Value Fund and Value Fund) for the year
ended March 31, 2005 (on which we have issued our report dated May 17, 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, and not to provide assurance on the Company's
internal control.

The management of the Company 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 any internal control, misstatements due to
error or fraud may occur and not be detected.  Also, projections of any
evaluation of internal control to future periods are subject to the risk that
the internal control may become inadequate because of changes in conditions or
that the degree of compliance with policies or procedures may deteriorate.

Our consideration of the Company's internal control would not necessarily
disclose all matters in internal control that might be material weaknesses under
standards established by the Public Company Accounting Oversight Board (United
States).  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 the Company's internal control and its operation, including controls
for safeguarding securities, which we consider to be material weaknesses as
defined above as of March 31, 2005.

This report is intended solely for the information and use of the Company's
management, the Board of Trustees and Shareholders of Ivy 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/ Deloitte & Touche LLP
Kansas City, Missouri
May 17, 2005