IMPACT MANAGEMENT INVESTMENT TRUST
NSAR-B, EX-99, 2000-11-28
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To the Shareholders and Board of Trustees
IMPACT Management Investment Trust
IMPACT Total Return Portfolio

In planning and performing our audit of the financial statements of IMPACT Total
Return Portfolio a Series of IMPACT  Management  Investment  Trust, for the year
ended  September  30, 2000,  we  considered  it's  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 IMPACT Total Return  Portfolio is responsible for establishing
and maintaining internal control. In fulfilling this  responsibility,  estimates
and  judgements 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. These 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 weakness 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
it's operation, including controls for safeguarding securities, that we consider
to be material weakness as defined above as of September 30, 2000.

This report is intended solely for the  information  and use of management,  the
Board of Trustees of IMPACT  Management  Investment Trust and the Securities and
Exchange  Commission  and is not intended to be and should not be used by anyone
other than these specified parties.

Denver, Colorado                                   SPICER, JEFFRIES & CO.
October 27, 2000



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