EX-99.77B

To the Board of Trustees and Shareholders of
T. Rowe Price New America Growth Fund


In planning and performing our audit of the financial
statements of T. Rowe
Price New America Growth Fund (hereafter referred to as the
"Fund") for the
period ended December 31, 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, not to
provide assurance on 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 entity's
objective of preparing financial statements for external
purposes that are fairly
presented in conformity with generally accepted accounting
principles.  Those
controls include the safeguarding of assets against
unauthorized acquisition,
use or disposition.

Because of inherent limitations in internal control, errors
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 controls may
become inadequate
because of changes in conditions or that the effectiveness
of their design and
operation may deteriorate.

Our consideration of 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 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, 2001.

This report is intended solely for the information and use
of management and
the Board of Trustees of T. Rowe Price New America Growth
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.




PricewaterhouseCoopers LLP
Baltimore, Maryland
January 18, 2002

EX-99.77P

Report of Independent Accountants

To the Board of Directors and Management of T.
Rowe Price Associates, Inc.

We have examined management's assertion,
included in the accompanying Management
Statement Regarding Compliance with the
Application for, and the Orders of, Exemption
granted
by the Securities & Exchange Commission dated
November 22, 2000, ("Management
Statement"). The Management Statement asserts
that as of October 31, 2000, and for the period
from July 23, 1999, through October 31, 2000,
T. Rowe Price Associates, Inc. (the "Company")
has established and maintained procedures
reasonably designed to achieve compliance with
the
conditions set forth in the Application, dated
November 12, 1998, filed by the Company (Rel.
No.
IC - 23532) as amended on October 29, 1999,
(Rel. No. IC - 24116) and the Orders by the
Securities & Exchange Commission on December 8,
1998 (Rel.IC - 23590) and November 23,
1999, (Rel. IC - 24159), collectively, the
"Orders". Management is responsible for the
Company's compliance with those requirements.
Our responsibility is to express an opinion on
management's assertion about the Company's
procedures to achieve compliance with the
conditions of the Orders based on our
examination.

Our examination was made in accordance with
attestation standards established by the
American
Institute of Certified Public Accountants and,
accordingly, included examining, on a test
basis,
evidence about the Company's procedures to
achieve compliance with the Orders and
performing
such other procedures as we considered
necessary in the circumstances.  Our
examination
procedures included an assessment of the
establishment and maintenance of procedures
reasonably designed to achieve the following
objectives set forth in the Orders (all
capitalized
terms as defined in the Orders):
a) The Interfund Rate on all interfund loans is
higher than the Repo Rate and, if applicable
the
yield of the Reserve Investment Funds, but
lower than the Bank Loan Rate;
b) All Interfund loans comply with the
collateral requirements as set forth in the
Orders;
c) All interfund loans comply with the
percentage limitations on Interfund borrowing
and
lending;
d) Interfund borrowing and lending demand is
allocated in accordance with procedures
established by the funds' Board of Directors;
and
e) The interest rate on any interfund loan does
not exceed the interest rate on any third party
borrowings of a borrowing fund at the time of
the interfund loan.

We believe that our examination provides a
reasonable basis for our opinion.  Our
examination
does not provide a legal determination on the
T. Rowe Price Funds' compliance with specified
requirements of the Orders.

Because of inherent limitations in internal
control, errors or fraud may occur and not be
detected.
Also, projections of any evaluation of internal
control over the Interfund Lending Program to
future periods are subject to the risk that
internal control may become inadequate because
of
changes in conditions, or that the degree of
compliance with the control activities may
deteriorate.

In our opinion, management's assertion that T.
Rowe Price Associates, Inc. has established and
maintained procedures reasonably designed to
achieve compliance with the Orders as of
October
31, 2000, and for the period from July 23,
1999, through October 31, 2000, is fairly
stated, in all
material respects, based upon the criteria set
forth in the Orders and the accompanying
Management Statement.

This report is intended solely for the
information and use of the Boards of Directors
and
management of the T. Rowe Price Funds, and the
Securities & Exchange Commission and should
not be used for any other purposes.

PRICEWATERHOUSECOOPERS

PricewaterhouseCoopers LLP
Baltimore, Maryland
November 22, 2000