Omb Approval Omb Number: 3235-0570 Expires: September 30, 2007 Estimated average burden hours per response: 19.4 United States Securities and Exchange Commission Washington, D.C. 20549 Form N-CSR Certified Shareholder Report of Registered Management Investment Companies Investment Company Act file number: 811-05807 NAIC Growth Fund, Inc. (Exact name of registrant as specified in charter) 711 West 13 Mile Road, Madison Heights, MI 48071 (Address of principal executive offices) (zip code) Kenneth S. Janke, Chairman and President NAIC Growth Fund, Inc. 711 W. 13 Mile Road Madison Heights, MI 48071 (248) 583-6242 (Name and address of agent for service) Registrant's telephone number, including area code: (877) 275-6242 Date of fiscal year end: December 31 Date of reporting period: June 30, 2006 Item 1. Reports to Stockholders NAIC Growth Fund, Inc. Semi-Annual Report June 30, 2006 www.naicgrowthfund.com Contents Report to Shareowners 3 Statement of Assets and Liabilities 4 Statement of Operations 5 Statements of Changes in Net Assets 6 Financial Highlights 7 Portfolio of Investments 8 Notes to Financial Statements 11 2006 Annual Shareholders Meeting 15 Director Compensation 16 NAIC Growth Fund, Inc., Board of Directors 17 Shareowner Information 17 page 2 Report to Shareowners: June 30, 2006 With the world in an uproar and many political uncertainties, the stock market treaded water for the most part during the first half of the year. Oil prices continued at a high level and interest rates were increased on a regular basis. Even after the end of June, there were more upheavals in the Mideast with violence erupting between Israel and Lebanon. None of these events were positive signs for the stock market. Additions to the portfolio included 11,000 Biomet bringing the total to 28,000 shares; 8,000 Jack Henry & Associates (30,000); 5,000 Johnson & Johnson (20,000); 3,000 Medtronic (17,000); 4,000 McCormick (24,000), 10,000 Sysco (30,000) and 1,000 Washington Mutual (15,000). Sales reduced the number of stocks in the portfolio with Carlisle, ConAgra Foods, Diebold, Donaldson, First Industrial Real Estate, H.J. Heinz and Merck being sold in their entirety. There were also partial sales of 2,000 Johnson Controls and 10,000 O'Reilly Automotive, although we continue to hold 10,000 Johnson Controls and 30,000 O'Reilly Automotive. The result of the sales enabled the Board of Directors to declare a 50 cent per share capital gain distribution to shareowners that was payable on July 6, 2006. Directors believe the shareholders should reap the benefits of a portion of our Fund's capital gains. We would also like to inform you that James M. Lane has recently retired from the Board of Directors. We greatly appreciate his many years of service to the Fund and wish him well. Mr. Robert M. Bilkie, Jr., 45, was appointed to serve the remainder of Mr. Lane's term on the Board and on the audit committee. During the past twenty- two years, Mr. Bilkie has been the President and CEO of Sigma Investment Counselors, Inc. (provides investment advisory services to high net worth individuals). The Board of Directors has authorized the repurchase on the open market of up to 100,000 of the Fund's outstanding shares of common stock. Based on current market prices we believe our shares are undervalued and the repurchase program is a good investment of available funds. The shares authorized to be repurchased are to be purchased from time to time as market and business conditions warrant. (signature) Kenneth S. Janke Chairman and President page 3 NAIC Growth Fund, Inc. Statement of Assets and Liabilities As of June 30, 2006 (unaudited) ASSETS Investment securities - at market value (cost $13,516,654) $ 24,033,670 Short-term investments - at amortized cost 995,674 Cash and cash equivalents 2,199,886 Dividends and interest receivable 36,902 Prepaid insurance 2,011 27,268,143 LIABILITIES Dividends payable 1,396,168 Accounts payable 12,757 Advisor fees payable 19,417 Accrued expenses 7,356 1,435,698 TOTAL NET ASSETS $ 25,832,445 SHAREOWNERS' EQUITY Common stock-par value $0.001 per share; authorized 50,000,000 shares, outstanding 2,792,336 shares $ 2,794 Additional paid-in capital 14,783,011 Undistributed net investment income 100,881 Undistributed net realized gain on investments 428,743 Unrealized appreciation of investments 10,517,016 SHAREOWNERS' EQUITY $ 25,832,445 NET ASSET VALUE PER SHARE $ 9.25 See notes to financial statements page 4 NAIC Growth Fund, Inc. Statement of Operations For the Period Ended June 30, 2006 (unaudited) INVESTMENT INCOME Interest $ 24,741 Dividends 263,753 288,494 EXPENSES Advisory fees 103,518 Legal fees 32,016 Transfer agent 14,210 Insurance 12,448 Printing 5,106 Other fees and expenses 4,656 Mailing and postage 4,496 Directors' fees and expenses 4,125 Audit fees 3,950 Custodian fees 3,903 Annual shareowners' meeting 2,537 Taxes 600 Total Expenses 191,565 Net investment income 96,929 REALIZED AND UNREALIZED GAIN ON INVESTMENTS Realized gain on investments: Proceeds from sale of investment securities 4,454,567 Cost of investment securities sold 2,629,656 Net realized gain on investments 1,824,911 Unrealized appreciation of investments: Unrealized appreciation at beginning of year 11,969,788 Unrealized appreciation at end of period 10,517,016 Net change in unrealized appreciation on investments (1,452,772) Net realized and unrealized gain on investments 372,139 NET INCREASE FROM OPERATIONS $ 469,068 See notes to financial statements Page 5 NAIC Growth Fund, Inc. Statements of Changes in Net Assets June 30, 2006 year ended (unaudited) December 31, 2005 FROM OPERATIONS: Net investment income $ 96,929 $ 191,572 Net realized gain on investments 1,824,911 266,791 Net change in unrealized appreciation on investments (1,452,772) (118,197) Net increase/(decrease) from operations 469,068 340,166 DISTRIBUTIONS TO STOCKHOLDERS FROM: Net investment income -- 193,385 Net realized gain from investment transactions 1,396,168 266,791 Total distributions 1,396,168 460,176 FROM CAPITAL STOCK TRANSACTIONS: Dividend reinvestment -- -- Cash purchases -- 6,693 Net increase from capital stock transactions -- 6,693 Net increase/(decrease) in net assets (927,100) (113,317) TOTAL NET ASSETS: Beginning of year 26,759,545 $26,872,862 End of period (including undistributed net investment income of $100,881 and 3,952, respectively) $25,832,445 $26,759,545 Shares: Shares issued to common stockholders under the dividend reinvestment plan and cash purchase plan -- 364,830 Shares at beginning of year 2,792,336 2,427,506 Shares at end of period 2,792,336 2,792,336 See notes to financial statements page 6 NAIC Growth Fund, Inc. Financial Highlights (a) For the periods ended: June 30, 2006 (unaudited) 2005 2004 2003 2002 2001 Net asset value at beginning of year $9.58 $9.63 $8.99 $7.90 $9.63 $10.40 Net investment income .03 .07 .01 .01 .02 .03 Net realized and unrealized gain (loss) on investments .14 .05 .81 1.39 (1.28) (.22) Total from investment operations .17 .12 .82 1.40 (1.26) (.19) Distribution from: Net investment income (.00) (.07) (.01) (.01) (.02) (.03) Realized gains (.50) (.10) (.17) (.30) (.45) (.55) Total distributions (.50) (.17) (.18) (.31) (.47) (.58) Net asset value at end of period $9.25 $9.58 $9.63 $8.99 $7.90 $9.63 -------------------------------------------------------------------------- Per share market value, end of period last traded price (b) $8.00 $8.70 $7.83 $8.26 $8.65 $9.35 Total Investment Return: Based on market value 1 year (annualized) (5.71%) 13.20% (3.31%) (1.33%) 2.10% 3.60% 5 year (.64%) 2.70% 6.65% 7.81% 1.79% 11.19% 10 year 7.49% 9.01% 13.45% 13.77% 14.28% 13.98% from inception 8.93% 9.44% 9.18% 10.17% 11.15% 11.97% Based on net asset value 1 year (annualized) 3.96% 1.34% 9.26% 17.69% (13.81%) (1.68%) 5 year 2.80% 2.00% 5.64% 5.42% 5.64% 13.85% 10 year 9.21% 8.97% 13.48% 12.83% 11.40% 14.21% from inception 9.92% 10.12% 10.75% 10.86% 10.34% 12.73% Net assets, end of year (000's)$25,832.4 $26,759.5 $26,872.9 $24,501.2 $20,555.3 $23,909.2 Ratios to average net assets annualized: Ratio of expenses to average net assets 1.40% 1.46% 1.80% 1.79% 1.61% 1.57% Ratio of net investment income to average net assets 0.71% 0.72% 0.11% 0.06% 0.17% 0.32% Portfolio turnover rate 5.93% 3.51% 6.53% 11.31% 11.19% 1.77% Average commission rate paid per share $0.065 $0.075 $0.095 $0.125 $0.125 $0.125 (a) All per share data for 2001-2005 has been restated to reflect the effect of a 15% stock dividend which was declared on April 21, 2005 and paid on May 23, 2005 to shareholders of record on May 13, 2005. (b) If there was no sale on the valuation date, the bid price for each such date is shown. Price obtained from Chicago Stock Exchange. See notes to financial statements page 7 NAIC Growth Fund, Inc. Portfolio of Investments - June 30, 2006 (unaudited) % Common Stock Shares Cost Market 3.6 Auto Replacement O'Reilly Auto* 30,000 $189,637 $935,700 Total $935,700 13.5 Banking Citigroup 22,000 368,635 1,061,500 Comerica, Inc. 10,000 404,669 519,900 Huntington Banc. 25,000 238,023 589,900 JP Morgan Chase 15,000 396,347 630,000 Synovus Financial 27,000 317,651 723,060 Total 3,523,960 4.0 Beverages - Soft Drinks PepsiCo 17,000 433,218 1,020,680 Total 1,020,680 3.2 Building Products Johnson Controls 10,000 85,823 822,200 Total 822,200 3.7 Chemicals RPM 25,000 287,099 450,000 Sigma Aldrich 7,000 213,317 508,480 Total 958,480 3.7 Consumer Products Colgate-Palmolive 16,000 469,850 958,400 Total 958,400 3.1 Electrical Equipment General Electric 24,000 441,341 791,040 Total 791,040 10.6 Ethical Drugs Abbott Laboratories 20,000 860,150 872,200 Johnson & Johnson 20,000 915,045 1,198,400 Pfizer, Inc. 28,000 606,755 657,160 Total 2,727,760 8.3 Financial Services CIT Group 10,000 392,785 522,900 State Street Boston 16,000 436,700 929,440 Washington Mutual 15,000 609,130 683,700 Total 2,136,040 page 8 3.1 Food McCormick & Co. 24,000 347,055 805,200 Total 805,200 3.6 Food Wholesale Sysco 30,000 448,328 916,800 Total 916,800 11.7 Hospital Supplies Biomet Corp. 28,000 573,428 876,120 Medtronic 17,000 850,214 797,640 Polymedica 12,000 346,237 431,520 Stryker Corp. 22,000 180,012 926,420 Total 3,031,700 3.6 Insurance AFLAC, Inc. 20,000 143,906 927,000 Total 927,000 2.3 Information Technology Jack Henry & Assoc. 30,000 554,299 589,800 Total 589,800 3.2 Machinery Emerson Electric Co. 10,000 335,278 838,100 Total 838,100 5.7 Multi Industry Pentair 18,000 280,288 615,420 Teleflex 16,000 545,608 864,320 Total 1,479,740 2.7 Office Supplies Avery Dennison 12,000 666,064 696,720 Total 696,720 3.4 Restaurant Wendy's 15,000 579,762 874,350 Total 874,350 page 9 93.0% Investment Securities $13,516,654 $24,033,670 Short-term Investments 3.9 United States Treasury Bills, Maturing 7/27/2006 $995,674 8.7 Misc. Cash Equivalents 2,238,799 ------ --------------- 12.6% $3,234,473 Total Investments $27,268,143 (5.6) All other assets less liabilities (1,435,698) ------ --------------- 100% TOTAL NET ASSETS $25,832,445 NAIC Growth Fund, Inc. Portfolio of Investments - June 30, 2006 (unaudited) Top Ten Holdings - NAIC Growth Fund, 06/30/06 Company Market Value % of Portfolio Investments Johnson & Johnson $1,198,400 5.0 Citigroup 1,061,500 4.4 PepsiCo 1,020,680 4.2 Colgate-Palmolive 958,400 4.0 O'Reilly Auto 935,700 3.9 State Street 929,440 3.9 Aflac Incorporated 927,000 3.9 Stryker 926,420 3.9 Sysco 916,800 3.8 Biomet Corp. 876,120 3.6 Summary of Investment Position as % of Total Investmnets 6/30/2006 (Graph) Equities-Common Stock 88.3% Fixed Income-U.S. Treasury Bills 3.7% Cash 8.1% See notes to financial statements *Non-income producing security page 10 NAIC Growth Fund, Inc. Notes to Financial Statements (1) ORGANIZATION The NAIC Growth Fund, Inc. (the "Fund") was organized under Maryland law on April 11, 1989 as a diversified closed-end investment company under the Investment Company Act of 1940. The Fund commenced operations on July 2, 1990. (2) SIGNIFICANT ACCOUNTING POLICIES The following is a summary of the significant accounting policies followed by the Fund not otherwise set forth in the notes to financial statements: Dividends and Distributions - Dividends from the Fund's net investment income and realized net long- and short-term capital gains will be declared and distributed at least annually. Shareowners may elect to participate in the Dividend Reinvestment and Cash Purchase Plan (see Note 4). Investments - Investments in equity securities are stated at market value, which is determined based on quoted market prices or dealer quotes. If no such prices are available on the valuation date, the Board of Directors has determined the most recent market prices be used. Pursuant to Rule 2a-7 of the Investment Company Act of 1940, the Fund utilizes the amortized cost method to determine the carrying value of short-term debt obligations. Under this method, investment securities are valued for both financial reporting and Federal tax purposes at amortized cost, which approximates fair value. Any discount or premium is amortized from the date of acquisition to maturity. Investment security purchases and sales are accounted for on a trade date basis. Interest income is accrued on a daily basis while dividends are included in income on the ex-dividend date. Use of Estimates - The preparation of financial statements in conformity with accounting principles generally accepted in the united states requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. Federal Income Taxes - The Fund intends to comply with the general qualification requirements of the Internal Revenue Code applicable to regulated investment companies. The Fund intends to distribute at least 90% of its taxable income, including net long-term capital gains, to its shareowners. In order to avoid imposition of the excise tax applicable to regulated investment companies, it is also the Fund's intention to declare as dividends in each calendar year at least 98% of its net investment income and 98% of its net realized capital gains plus undistributed amounts from prior years. page 11 The following information is based upon Federal income tax cost of portfolio investments as of June 30, 2006: Gross unrealized appreciation $ 10,569,590 Gross unrealized depreciation (52,574) ---------- Net unrealized appreciation $ 10,517,016 Federal income tax cost $ 13,516,654 Expenses - The Fund's service contractors bear all expenses in connection with the performance of their services. The Fund bears all expenses incurred in connection with its operations including, but not limited to, management fees (as discussed in Note 3), legal and audit fees, taxes, insurance, shareowner reporting and other related costs. Such expenses will be charged to expense daily as a percentage of net assets. The Advisory Agreement provides that the Fund may not incur annual aggregate expenses in excess of two percent (2%) of the first Ten Million Dollars of the Fund's average net assets, one and one-half percent (1 1/2%) of the next Twenty Million Dollars of the average net assets, and one percent (1%) of the remaining average net assets for any fiscal year. Any excess expenses shall be the responsibility of the Investment Adviser, and the pro rata portion of the estimated annual excess expenses will be offset against the Investment Adviser's monthly fee. (3) MANAGEMENT ARRANGEMENTS Investment Adviser - Growth Fund Advisor, Inc., serves as the Fund's Investment Adviser subject to the Investment Advisory Agreement, and is responsible for the management of the Fund's portfolio, subject to review by the board of directors of the Fund. For the services provided under the Investment Advisory Agreement, the Investment Adviser receives a monthly fee at an annual rate of three-quarters of one percent (0.75%) of the average weekly net asset value of the Fund, during the times when the average weekly net asset value is at least $3,800,000. The Investment Adviser will not be entitled to any compensation for a week in which the average weekly net asset value falls below $3,800,000. Custodian and Plan Agent - LaSalle Bank, NA (LB) serves as the Fund's custodian pursuant to the Custodian Agreement. As the Fund's custodian, LB receives fees and compensation of expenses for services provided including, but not limited to, an annual account charge, annual security fee, security transaction fee and statement of inventory fee. American Stock Transfer and Trust Company serves as the Fund's transfer agent and dividend disbursing agent pursuant to Transfer Agency and Dividend Disbursement Agreements. American Stock Transfer and Trust Company receives fees for services provided including, but not limited to, account maintenance fees, activity and transaction processing fees and reimbursement of out-of-pocket expenses such as forms and mailing costs. page 12 (4) DIVIDEND REINVESTMENT AND CASH PURCHASE PLAN The Fund has a Dividend Reinvestment and Cash Purchase Plan (the "Plan") which allows shareowners to reinvest dividends paid and make additional contributions. Under the Plan, cash dividends and voluntary cash payments will be invested in shares purchased in the open market. In the event the Plan agent is unable to complete its acquisition of shares to be purchased on the open market by the end of the thirtieth (30th) day following receipt of the cash dividends from the Fund, any remaining funds will be returned to the participants on pro rata basis. In the event the Plan agent is unable to complete its acquisition of shares to be purchased from additional contributions on the open market by the end of the twentieth (20th) day following the Investment Date, any remaining funds will be returned to the participants on a pro rata basis. The number of shares credited to each shareowner participant's account will be based upon the average purchase price for all shares purchased. (5) DISTRIBUTIONS TO SHAREOWNERS On June 15, 2006, a distribution of $0.50 per share aggregating $1,396,168 was declared from realized gains. the divideND WAS PAID ON July 6, 2006, to shareowners of record on June 26, 2006. The tax character of distributions paid during 2005 and 2004 was as follows: 2005 2004 Distributions paid from: Ordinary income $193,385 $19,792 Long-term capital gain 266,791 455,020 ---------- --------- $460,176 $474,812 As of June 30, 2006, the components of distributable earnings on a tax basis were as follows: Undistributed ordinary income $100,881 Undistributed realized gain on investments 428,743 Unrealized appreciation 10,517,016 page 13 6) INVESTMENT TRANSACTIONS Purchases and sales of securities, other than short- term securities for the period ended June 30, 2006, were $1,568,415 and $4,454,5678, respectively. (7) FINANCIAL HIGHLIGHTS The Financial Highlights present a per share analysis of how the Fund's net asset value has changed during the years presented. Additional quantitative measures expressed in ratio form analyze important relationships between certain items presented in the financial statements. The Total Investment Return based on market value assumes that shareowners bought into the Fund at the bid price and sold out of the Fund at the bid price. In reality, shareowners buy into the Fund at the ask price and sell out of the Fund at the bid price. Therefore, actual returns may differ from the amounts stated. page 14 2006 ANNUAL SHAREHOLDERS MEETING The 2006 annual meeting of shareholders was held on April 20, 2006 for the following purposes: 1. To elect a Board of eight (8) Directors; 2. To ratify or reject the selection of Plante & Moran, PLLC as independent registered public accountants of the Fund for the calendar year ending December 31, 2006. The following Directors were elected for Proposal 1: Thomas E. O'Hara, Kenneth S. Janke, Lewis A. Rockwell, Peggy L. Schmeltz, Carl A. Holth, Benedict J. Smith, James M. Lane, and Luke E. Sims. For Proposal 2, shareholders ratified the selection of Plante & Moran, PLLC as independent registered public accountants of the Fund. Tabulation Report Proposal 1 - Election of Directors For Against Abstain Withheld Thomas E. O'Hara 1,797,676 157,689 Kenneth S. Janke 1,843,375 111,989 Lewis A. Rockwell 1,794,265 161,099 Peggy L. Schmeltz 1,841,465 113,900 Carl A. Holth 1,858,543 96,821 Benedict J. Smith 1,822,047 133,318 James M. Lane 1,857,270 98,095 Luke E. Sims 1,894,992 60,372 Proposal 2 - Selection of Plante & Moran, PLLC 1,909,886 28,605 16,873 Total shares issued and outstanding on record date: 2,792,336 page 15 Compensation The following table sets forth the aggregate compensation paid to all directors through June 30, 2006. Directors also receive reimbursement for out-of-pocket expenses relating to attendance at meetings of the Fund. No officer of the Fund received compensation from the Fund through June 30, 2006 in his capacity as an officer of the Fund. Directors Who Are Interested Persons of the Fund Kenneth S. Janke Chaiman, President, Treasurer and Director Aggregate Compensation from Fund* None Pension or Retirement Benefits Accrued as Part of Fund Expenses None Estimated Annual Benefits Upon Retirement None Total Compensation from fund and Complex Paid to Directors** None Thomas E. O'Hara Director Aggregate Compensation from Fund* None Pension or Retirement Benefits Accrued as Part of Fund Expenses None Estimated Annual Benefits Upon Retirement None Total Compensation from fund and Complex Paid to Directors** None Lewis A. Rockwell Secretary and Director Aggregate Compensation from Fund* $600 Pension or Retirement Benefits Accrued as Part of Fund Expenses None Estimated Annual Benefits Upon Retirement None Total Compensation from fund and Complex Paid to Directors** $600 Peggy Schmeltz Director Aggregate Compensation from Fund* $600 Pension or Retirement Benefits Accrued as Part of Fund Expenses None Estimated Annual Benefits Upon Retirement None Total Compensation from fund and Complex Paid to Directors** $600 Directors Who Are Not Interested Persons of the Fund Carl A. Holth Director Aggregate Compensation from Fund* $600 Pension or Retirement Benefits Accrued as Part of Fund Expenses None Estimated Annual Benefits Upon Retirement None Total Compensation from Fund and Complex Paid to Directors** $600 Benedict M. Smith Director Aggregate Compensation from Fund* $600 Pension or Retirement Benefits Accrued as Part of Fund Expenses None Estimated Annual Benefits Upon Retirement None Total Compensation from Fund and Complex Paid to Directors** $600 Luke E. Sims Director Aggregate Compensation from Fund* $600 Pension or Retirement Benefits Accrued as Part of Fund Expenses None Estimated Annual Benefits Upon Retirement None Total Compensation from Fund and Complex Paid to Directors** $600 Robert M. Bilkie Director Aggregate Compensation from Fund* $0 Pension or Retirement Benefits Accrued as Part of Fund Expenses None Estimated Annual Benefits Upon Retirement None Total Compensation from Fund and Complex Paid to Directors** $0 *All amounts shown are for service as a director **The Fund is not part of any fund complex. page 16 NAIC Growth Fund, Inc. Board of Directors Kenneth S. Janke Chairman and President, Bloomfield Hills, MI Thomas E. O'Hara Director, Highland Beach, FL Lewis A. Rockwell Secretary, Grosse Pointe Shores, MI Peggy L. Schmeltz Director, Bowling Green, OH Carl A. Holth Director, Clinton Twp., MI Benedict J. Smith Director, Birmingham, MI Luke E. Sims Director, Milwaukee, WI Robert M. Bilkie Director, Southfield, MI Shareowner Information The ticker symbol for the NAIC Growth Fund, Inc., on the Chicago Stock Exchange is GRF. You may wish to visit the Chicago Stock Exchange web site at www.chicagostockex.com. The dividend reinvestment plan allows shareowners to automatically reinvest dividends in Fund common stock without paying commissions. Once enrolled, you can make additional stock purchases through monthly cash deposits ranging from $50 to $1,000. For more information, request a copy of the Dividend Reinvestment Service for Stockholders of NAIC Growth Fund, Inc., from American Stock Transfer and Trust Company, P.O. Box 922 Wall Street Station, New York, NY 10038, Telephone 1- 800-937-5449. Questions about dividend checks, statements, account consolidation, address changes, stock certificates or transfer procedures write American Stock Transfer and Trust Company, P.O. Box 922 Wall Street Station, New york, NY 10038, Telephone 1-800-937-5449. The Fund files its complete schedule of portfolio holdings with Securities and Exchange Commission for the first and third quarters of each fiscal year on Form N-Q. The Fund's Form N-Q are available on the Commission's website at http://sec.gov, on the Fund's website at http://www.naicgrowthfund.com under the heading "SEC Edgar Filings" and upon request by calling 1-877-275-6242. The Fund's Forms N-Q may be reviewed and copied at the Commission's Public Reference Room in Washington, D.C., and information on the operation of the Public Reference Room may obtained by calling 1-800-SEC-0330. page 17 A description of the policies and procedures that the Fund uses to determine how to vote proxies relating to portfolio securities is available (1) without charge, upon request, by calling 877-275-6242; (2) on the Fund's website at www.naicgrowthfund.com; and (3) on the Securities and Exchange Commission website at www.sec.gov. Information regarding how the Fund voted proxies relating to portfolio securities during the most recent twelve month period ended June 30, 2006 is available (1) without charge, upon request by calling 1-877-275-6242 or on the Fund's website at http://www.naicgrowthfund.com and (2) on the Commission's website at http://www.sec.gov. Shareowners or individuals wanting general information or having questions, write NAIC Growth Fund, Inc., P.O. Box 220, Royal Oak, Michigan 48068. Telephone 877-275-6242 or visit us at our website at www.naicgrowthfund.com. page 18 ITEM 2. CODE OF ETHICS. Not required for the semi-annual report ITEM 3. AUDIT COMMITTEE FINANCIAL EXPERT. Not required for the semi-annual report ITEM 4. PRINCIPAL ACCOUNTANT FEES AND SERVICES. Not required for the semi-annual report ITEM 5. AUDIT COMMITTEE OF LISTED REGISTRANTS. Not required for the semi-annual report ITEM 6. Schedule of Investments The Fund's schedule of investments is included as part of the report to shareholders filed under Item 1 of the this Form. ITEM 7. DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED END MANAGEMENT INVESTMENT COMPANIES. Not required for the semi-annual report. Item 8. PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANIES Not required for this semi-annual report. ITEM 9. PURCHASE OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND AFFILIATED PURCHASERS. Not applicable. ITEM 10. SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS. Not applicable. ITEM 11. CONTROLS AND PROCEDURES. (i) As of August 15, 2006, an evaluation of the effectiveness of the registrant's disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) was performed under the supervision and with the participation of the registrant's President (Principal Executive Officer) and Accountant (person performing the functions of the Principal Financial Officer). Based on that evaluation, the registrant's President and Accountant concluded that the registrant's controls and procedures are effectively designed to insure that information required to be disclosed by the registrant in this Form N-CSR is recorded, processed, summarized and reported within the time periods required by the Commission's rules and forms, and that information required to be disclosed in the reports that the registrant files on Form N-CSR is accumulated and communicated to the registrant's management, including its principal executive and principal financial officers, or persons performing similar functions as appropriate, to allow timely decisions regarding required disclosure. (ii) There has been no change in the registrants's internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act) that occurred during the second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant's internal control over financial reporting. ITEM 12. EXHIBITS: (A)(1) Not applicable. (A)(2) Separate certification of principal executive officer and principal financial officer as required by Rule 30a-2 under the Act. (A)(3) Not applicable. (B) Certification Pursuant to 18 U.S.C. Section 1350. SIGNATURES Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized. NAIC GROWTH FUND, INC. By: /s/ Kenneth S. Janke ---------------------- Kenneth S. Janke Chairman and President Date: August 29, 2006 Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated. By: /s/ Kenneth S. Janke ---------------------- Kenneth S. Janke Chairman and President Date: August 29, 2006 By: /s/ Calvin George --------------------- Calvin George Accountant (Principal Financial Officer) Date: August 29, 2006