<PAGE>
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
RE: SM&R GROWTH FUND, INC.
File Numbers: 002-10305
811-00623
Dear Sir or Madam:
Pursuant to paragraph (j) of Rule 497 (the "Rule") under the Securities
Act of 1933, the captioned registrant hereby certifies, in lieu of filing
under paragraph (c) of the Rule, that the forms of prospectus and Statement
of Additional Information that would have been filed under paragraph (c)
would not have differed from that contained in the registrant's most recent
amendment to the registration statement, Post-Effective Amendment No. 98.
SM&R GROWTH FUND, INC.
By: /s/ Teresa E. Axelson
------------------------------------
Teresa Axelson, Secretary
April 29, 1999