REPORT OF INDEPENDENT REGISTERED PUBLIC
ACCOUNTING FIRM


To the Board of Trustees and the Shareholders of Dunham
Funds


In planning and performing our audits of the financial statements of
Dunham Corporate/Government Bond Fund, Dunham Floating Rate
Bond Fund, Dunham High-Yield Bond Fund, Dunham International
Opportunity Bond Fund, Dunham Large Cap Value Fund, Dunham
Small Cap Value Fund, Dunham Focused Large Cap Growth Fund,
Dunham Small Cap Growth Fund, Dunham Emerging Markets Stock
Fund, Dunham International Stock Fund, Dunham Dynamic Macro
Fund, Dunham Long/Short Credit Fund, Dunham Monthly
Distribution Fund, and Dunham Real Estate Stock Fund, each a
series of shares of beneficial interest in Dunham Funds (the Funds,
as of October 31, 2021, and for the year then ended, in accordance
with the standards of the Public Company Accounting Oversight
Board (United States) (PCAOB), we considered the Funds internal
control over financial reporting, including controls over safeguarding
securities, as a basis for designing our auditing procedures for the
purpose of expressing our opinion on the financial statements and
to comply with the requirements of Form N-CEN, but not for the
purpose of expressing an opinion on the effectiveness of the Funds
internal control over financial reporting.  Accordingly, we express no
such opinion.

The management of the Funds is responsible for establishing and
maintaining effective internal control over financial reporting.  In
fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and
related costs of controls.  A funds internal control over financial
reporting is a process designed to provide reasonable assurance
regarding the reliability of financial reporting and the preparation of
financial statements for external purposes in accordance with
accounting principles generally accepted in the United States of
America (GAAP).  A funds internal control over financial reporting
includes those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately and
fairly reflect the transactions and dispositions of the assets of the
fund; (2) provide reasonable assurance that transactions are
recorded as necessary to permit preparation of the financial
statements in accordance with GAAP, and that receipts and
expenditures of the fund are being made only in accordance with
authorizations of management and trustees of the fund; and (3)
provide reasonable assurance regarding prevention or timely
detection of unauthorized acquisition, use or disposition of a funds
assets that could have a material effect on the financial statements.

Because of inherent limitations, internal control over financial
reporting may not prevent or detect misstatements.  Also,
projections of any evaluation of effectiveness to future periods are
subject to the risk that controls may become inadequate because of
changes in conditions or that the degree of compliance with the
policies or procedures may deteriorate.

A deficiency in internal control over financial reporting exists when
the design or operation of a control does not allow management or
employees, in the normal course of performing their assigned
functions, to prevent or detect misstatements on a timely basis.  A
material weakness is a deficiency, or combination of deficiencies, in
internal control over financial reporting, such that there is a
reasonable possibility that a material misstatement of the Funds
annual or interim financial statements will not be prevented or
detected on a timely basis.


Our consideration of the Funds internal control over financial
reporting was for the limited purpose described in the first paragraph
and would not necessarily disclose all deficiencies in internal control
that might be material weaknesses under standards established by
the PCAOB.  However, we noted no deficiencies in the Funds
internal control over financial reporting and its operation, including
controls over safeguarding securities, that we consider to be a
material weakness, as defined above, as of October 31, 2021.

This report is intended solely for the information and use of
management and the shareholders of Dunham
Corporate/Government Bond Fund, Dunham Floating Rate Bond
Fund, Dunham High-Yield Bond Fund, Dunham International
Opportunity Bond Fund, Dunham Large Cap Value Fund, Dunham
Small Cap Value Fund, Dunham Focused Large Cap Growth Fund,
Dunham Small Cap Growth Fund, Dunham Emerging Markets Stock
Fund, Dunham International Stock Fund, Dunham Dynamic Macro
Fund, Dunham Long/Short Credit Fund, Dunham Monthly
Distribution Fund, and Dunham Real Estate Stock Fund, the Board
of Trustees of Dunham Funds and the Securities and Exchange
Commission and is not intended to be and should not be used by
anyone other than these specified parties.



BBD, LLP


Philadelphia, Pennsylvania
December 30, 2021