SPARROW FUNDS
NSAR-B, EX-99.77B, 2000-10-31
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Board of Trustees
Sparrow Funds:

In planning and  performing  our audit of the  financial  statements  of Sparrow
Funds for the year ended August 31, 2000,  we  considered  its internal  control
structure,  including  procedures  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 the internal control structure.

The management of Sparrow Funds is responsible for  establishing and maintaining
an internal control structure. In fulfilling this responsibility,  estimates and
judgments by management are required to assess the expected benefits and related
costs  of  internal  control  structure  policies  and  procedures.  Two  of the
objectives  of an internal  control  structure  are to provide  management  with
reasonable, but not absolute, assurance that assets are safeguarded against loss
from unauthorized use or disposition and transactions are executed in accordance
with management's  authorization and recorded properly to permit  preparation of
financial   statements  in  conformity   with  generally   accepted   accounting
principles.

Because of inherent  limitations in any internal  control  structure,  errors or
irregularities  may  occur  and may not be  detected.  Also,  projection  of any
evaluation of the structure 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 the  internal  control  structure  would not  necessarily
disclose all matters in the internal  control  structure  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 the specific internal control structure elements does not reduce to
a relatively  low level the risk that errors or  irregularities  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 the internal control structure,  including procedures for safeguarding
securities,  that we consider to be material  weaknesses  as defined above as of
August 31, 2000.

This report is intended solely for the information and use of management and the
Securities and Exchange Commission.

McCurdy & Associates CPA's, Inc.
Westlake, Ohio
September 14, 2000



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