NOAH INVESTMENT GROUP INC
NSAR-B, EX-99, 2000-12-29
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SANVILLE & COMPANY
Certified Public Accountants
1514 Old York Road
Abington, PA  19001

(215) 884-8460

To the Shareholders and Board of
Directors of The Noah Investment Group, Inc.

In planning and performing our audit of the financial statements of The Noah
Fund (the "Fund"), a series of the Noah Investment Group, Inc. for the year
ended October 31, 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 the Fund is responsible for establishing and maintaining
internal control.  In fulfilling this responsibility, estimates and
judgements 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 focused by error or
fraud 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 internal control and its
operation, including controls 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,
the Board of Directors of The Noah Fund, and the Securities and
Exchange Commission.


Abington, Pennsylvania					                    	Sanville & Company
December 5, 2000	                               Certified Public Accountants






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