EX-99.77B ACCT LTTR

Independent Auditor's Report

To the Board of Directors and Shareowners
NAIC Growth Fund, Inc.

We have audited the accompanying statement of assets and
liabilities of NAIC Growth Fund, Inc., including the portfolio of
investments, as of December 31, 2005 and the related statement of
operations for the year then ended and the statement of changes in
net assets and financial highlights for each of the two years in the
period then ended. These financial statements and financial
highlights are the responsibility of the Fund's management. Our
responsibility is to express an opinion on these financial
statements and financial highlights based on our audit.  The
financial highlights of NAIC Growth Fund, Inc. for each of the two
years in the period ended December 31, 2001 were audited by
other auditors who have ceased operations and whose most recent
report dated January 4, 2002 expressed an unqualified opinion on
the financial statements containing those financial highlights.

We conducted our audit in accordance with the standards of the
Public Company Accounting Oversight Board (United States).  Those
standards require that we plan and perform the audit to obtain
reasonable assurance about whether the financial statements and
financial highlights are free of material misstatement. An audit
includes examining, on a test basis, evidence supporting the
amounts and disclosures in the financial statements. Our
procedures included confirmation of securities owned as of
December 31, 2005 by correspondence with the custodian. An
audit also includes assessing the accounting principles used and
significant estimates made by management, as well as evaluating
the overall financial statement presentation. We believe that our
audit provides a reasonable basis for our opinion.

In our opinion, the financial statements and financial highlights
referred to above present fairly, in all material respects, the
financial position of NAIC Growth Fund, Inc. as of December 31,
2005, the results of its operations for the year then ended, and the
statement of changes in net assets and financial highlights for each
of the two years in the period then ended, in conformity with
accounting principles generally accepted in the United States of
America.




January 5, 2006			Plante & Moran, PLLC

EX-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
Fund's common stock are required to file initial reports of
ownership and reports of changes in ownership of the Fund's
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, 2005 all such reports were timely filed.