Independent Auditors' Report on Internal Accounting Control
The Board of Directors and Shareholders
AXP Progressive Fund Inc.:
In planning and performing our audits of the financial statements of AXP
Progressive Fund for the year ended September 30, 2000, we considered its
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 the internal control.
The management of AXP Progressive Fund, Inc. 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 control. 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, errors or irregularitie
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 the internal control would not necessarily disclose al
matters in the 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 internal control components 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 and its operation, including controls for safeguarding securities,
that we consider to be a material weakness as defined above.
This report is intended solely for the information and use of management, the
Board of Directors of AXP Progressive Inc., and the Securities and Exchange
Commission and is not intended to be and should not be used by anyone other
than these specified parties.
KPMG LLP
Minneapolis, Minnesota
November 3, 2000
