UPRIGHT INVESTMENTS TRUST
NSAR-B/A, EX-99.77KCHNGACCNT, 2001-01-11
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DESCRIPTION    Sub - Item 77K:     Changes in registrant's certifying accountant


Sub - Item 77K:      Changes in registrant's certifying accountant


           McCurdy &  Associates  CPA's.  Inc resigned as auditor of The Upright
Growth  Fund.  (the "fund")  prior to the close of the Fund's  fiscal year ended
September 30, 2000.  During the period McCurdy & Associates  CPA's.  Inc audited
the Fund, its report on the financial statements for the Fund did not contain an
adverse opinion or a disclaimer of opinion,  nor was it qualified or modified as
to uncertainty, audit scope, or accounting principles.

           Subsequent to the resignation of McCurdy & Associates CPA's. Inc, the
Fund's Board of Directors  approved the appointment of Baird,  Kurtz & Dobson to
become the auditor of the Fund as August 13, 2000.

           During the period  McCurdy & Associates  CPA's.  Inc audited the Fund
and the period preceding its resignation, the Fund did not have any disagreement
with McCurdy & Associates  CPA's.  Inc of the type that,  if not resolved to the
satisfaction  of McCurdy & Associates  CPA's.  Inc,  would have caused McCurdy &
Associates  CPA's.  Inc to have made a reference  to the  subject  matter of the
disagreement in connection with its report.

           During the period  McCurdy & Associates  CPA's.  Inc audited the Fund
and the  period  preceding  its  resignation,  there  were no events of the kind
identified in Item 304 (a) (1) (v) (A) - (D) of Regulation S - K.

           During  the  period   beginning  with  the  Fund's   commencement  of
operations and ending with the resignation of McCurdy & Associates  CPA's.  Inc,
neither the Fund,  nor someone on its behalf,  consulted  Baird,  Kurtz & Dobson
regarding any matter identified in Item 304 (a) (2) of Regulation S - K.



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