Independent Auditors' Report on Internal Accounting Control
The Board of Directors and Shareholders
Growth and Income Trust:
In planning and performing our audits of the financial statements
of Equity Income Portfolio, Total Return Portfolio,
Balanced Portfolio and Equity Portfolio (portfolios
within Growth and Income Trust)
for the year ended September 30, 2000,
we considered their 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 Growth and Income Trust 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,
errors or
irregularities 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 all 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 misstatements
caused 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 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 Growth and Income
Trust, 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
