Board of Directors and Shareholders
Valgro Funds, Inc.
In planning and performing our audit of the financial statements of Valgro
Funds, Inc. (the "Company") for the period from February 9, 2000 (date of
inception) to October 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 and not to provide
assurance on the intemal control structure.
The management of the Company 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 that transactions are executed in
accordance with management's authorization and recorded properly to permit
preparation of financial statements in conformity with accounting principles
generally accepted in the United States of America.
Because of inherent limitations in any internal control structure, errors or
irregularities may occur and 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
October 31, 2000.
This report is intended solely for the information and use of management and
the Securities and Exchange Commission.
Grant Thornton LLP
Chicago, Illinois
December 6, 2000
