Exhibit 77-Q1

EXHIBITS

(e) Form of Investment Management Agreement between the Registrant, on behalf of
the Fund,  and  Pilgrim  Investments,  Inc.  is  incorporated  by  reference  to
Post-Effective  Amendment No. 70 to the  Registration  Statement on Form N-1A as
filed on March 1, 2001.

(g) Form of Agreement  and Plan of  Reorganization  between the  Registrant,  on
behalf of the Fund,  and ING Funds  Trust,  on behalf of ING  Growth  and Income
Fund, is incorporated by reference to the Registration Statement on Form N-14 as
filed on December 19, 2000.