DOMINION FUNDS INC
NSAR-B, EX-99.77(B), 2000-08-29
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                      INDEPENDENT AUDITOR'S REPORT

To the Shareholders and

Board of Directors of
Dominion Funds, Inc.

In planning and performing our audit of the financial statements of the Dominion
Insight Growth Fund portfolio of Dominion Funds, Inc. for the year ended June
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 internal control.

The management of Dominion Funds, 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 controls. 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, error or fraud 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 internal control would not necessarily disclose all matters
in 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 misstatements caused by error or fraud in amounts that would be
material in relation to the financial statement 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
internal control and its operation, including controls for safeguarding
securities, that we consider to be material weaknesses as defined above as of
June 30, 2000.

This report is intended solely for the information and use of management, the
Board of Directors of Dominion Funds, Inc. and the Securities and Exchange
Commission.

                                        WALLACE SANDERS & COMPANY

Irving, Texas
July 18, 2000



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