PRUDENT BEAR FUNDS INC
NSAR-B, EX-99, 2000-11-22
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To the Shareholders and Board of Directors of
      Prudent Bear Funds, Inc.

In planning and performing our audits of the financial  statements and financial
highlights  of Prudent  Bear Fund and Prudent  Safe  Harbor  Fund  (constituting
Prudent  Bear Funds,  Inc.  and  hereafter  referred to as the  "Funds") for the
periods ended  September 30, 2000, we considered  the Funds'  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 Funds 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,  error 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 it may become  inadequate  because of
changes in conditions or that the  effectiveness of the 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 specific 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
September 30, 2000.

This  report is  intended  solely  for the  information  and use of the Board of
Directors,  management  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
Milwaukee, Wisconsin
November 17, 2000



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