Exhibit (i)(2)

                            [LETTERHEAD OF DECHERT]


November 9, 2001


Board of Directors
Pilgrim Investment Funds, Inc.
7337 E. Doubletree Ranch Road
Scottsdale, AZ 85258-2034

Re: Pilgrim Investment Funds, Inc., on behalf of Pilgrim MagnaCap Fund


Dear Ladies and Gentlemen:

We have acted as counsel to Pilgrim Investment Funds, Inc., a Maryland
corporation (the "Company"), and we have a general familiarity with the
Company's business operations, practices and procedures. You have asked for our
opinion regarding the issuance of shares of common stock by the Company in
connection with the registration of Class I shares on behalf of the Pilgrim
MagnaCap Fund, a series of the Company.

We have examined originals or certified copies, or copies otherwise identified
to our satisfaction as being true copies, of various corporate records of the
Company and such other instruments, documents and records as we have deemed
necessary in order to render this opinion. We have assumed the genuineness of
all signatures, the authenticity of all documents examined by us and the
correctness of all statements of fact contained in those documents.

On the basis of the foregoing, it is our opinion that the shares of common stock
of the Company registered under the Securities Act of 1933 in the Registration
Statement when issued in accordance with the terms described in the Registration
Statement as filed on November 9, 2001, will be duly and validly issued and
outstanding, fully paid and non-assessable.

We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to our firm as set forth under the
caption "Legal Counsel" in the above-referenced Registration Statement. In
giving such consent, 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