Exhibit 12(C)

                                  May 30, 2001

Pilgrim Investment Funds
7337 East Doubletree Ranch Road
Scottsdale, Arizona  85258-2034

Re:  Pilgrim Investment Funds
     (File No. 333-50844)

Dear Sirs:

     We hereby  consent to the  incorporation  by  reference  to our opinions as
exhibits to  Post-Effective  Amendment  No. 1 to the  Registration  Statement of
Pilgrim  Investment  Funds and to all references to our firm therein.  In giving
such  consent,  however,  we do not admit  that we are within  the  category  of
persons whose consent is required by Section 7 of the Securities Act of 1933, as
amended, and the rules and regulations thereunder.

                                        Very truly yours,

                                        /s/ Dechert