INDEPENDENT AUDITORS REPORT

To the Board of Trustees and Shareholders of the New England Zenith
Fund:

In planning and performing our audit of the financial statements
of the New England Zenith Fund  (the Fund) (comprising
respectively, the Back Bay Advisors Bond Income Series, Loomis
Sayles Small Cap Series, Alger Equity Growth Series, Capital
Growth Series, Harris Oakmark Mid Cap Value Series, Davis
Venture Value Series, Westpeak Growth and Income Series,
Westpeak Stock Index Series, Balanced Series, Back Bay
Advisors Managed Series, Salomon Brothers Strategic Bond
Opportunities Series, Salomon Brothers U.S. Government
Series, Back Bay Advisors Money Market Series, MFS
Investors Series, and MFS Research Managers Series
(the Series)) for the period ended December 31, 2000
(on which we have issued our report dated February 16, 2001),
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 Funds
internal control.

The management of the Fund 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 entitys 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 Funds internal control would not necessarily
disclose all matters in 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 due to 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 Funds internal control and its operation, including
controls for safeguarding securities, that we consider to be material
weaknesses as defined above as of December 31, 2000.

This report is intended solely for the information and use of management,
the Trustees and Shareholders of the New England Zenith Fund, and the
Securities and Exchange Commission and is not intended to be and should
not be used by anyone other than these specified parties.





Deloitte and Touche
Boston, Massachusetts
February 16, 2001