Report of Independent Registered
Public Accounting Firm

 To the Board of Directors and
Shareholders of Value Line Centurion Fund, Inc.

In planning and performing our audit of the financial
statements of Value Line Centurion Fund, Inc. (the
"Fund") as of and for the year ended December 31, 2019,
in accordance with the standards of the Public Company
Accounting Oversight Board (United States) (PCAOB),
we considered the Fund's 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 Fund's internal control over
financial reporting. Accordingly, we do not express an
opinion on the effectiveness of the Fund's internal control
over financial reporting.
The management of the Fund 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 company's 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 generally accepted accounting
principles. A company's 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 company; (2) provide
reasonable assurance that transactions are recorded as
necessary to permit preparation of financial statements in
accordance with generally accepted accounting principles,
and that receipts and expenditures of the company are
being made only in accordance with authorizations of
management and directors of the company; and (3)
provide reasonable assurance regarding prevention or
timely detection of unauthorized acquisition, use or
disposition of a company's assets that could have a
material effect on the financial statements.
Because of its 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 a combination of deficiencies, in internal
control over financial reporting, such that there is a
reasonable possibility that a material misstatement of the
company's annual or interim financial statements will not
be prevented or detected on a timely basis.
Our consideration of the Fund's 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 over financial reporting
that might be material weaknesses under standards
established by the PCAOB. However, we noted no
deficiencies in the Fund's internal control over financial
reporting and its
operation, including controls over safeguarding
securities, that we consider to be material weaknesses
as defined above as of December 31, 2019.

This report is intended solely for the information and
use of the Board of Directors of Value Line Centurion
Fund, Inc. and the Securities and Exchange Commission
and is not intended to be and should not be used by
anyone other than these specified parties.


/s/PricewaterhouseCoopers LLP
New York, New York
February 14, 2020