EX-99.77.B

                                                                   Exhibit 77(b)


                        REPORT OF INDEPENDENT ACCOUNTANTS


To the Board of Directors and Shareholders
  of ING Investment Funds, Inc.

In planning and performing our audit of the financial statements of ING High
Yield Fund, formerly Pilgrim High Yield Fund, one of the two funds comprising
ING Investment Funds, Inc., formerly Pilgrim Investment Funds, Inc., (the
"Fund") for the year ended March 31, 2002, we considered its internal control,
including control activities for safeguarding securities, in order to determine
our auditing procedures for the purpose of expressing our opinion on the
financial statements and to comply with the requirements of Form N-SAR, not to
provide assurance on internal control.

The management of the Fund is responsible for establishing and maintaining
internal control. In fulfilling this responsibility, estimates and judgments by
management are required to assess the expected benefits and related costs of
controls. Generally, controls that are relevant to an audit pertain to the
entity's objective of preparing financial statements for external purposes that
are fairly presented in conformity with generally accepted accounting
principles. Those controls include the safeguarding of assets against
unauthorized acquisition, use or disposition.

Because of inherent limitations in internal control, errors or fraud may occur
and not be detected. Also, projection of any evaluation of internal control to
future periods is subject to the risk that controls may become inadequate
because of changes in conditions or that the effectiveness of their design and
operation may deteriorate.

Our consideration of internal control would not necessarily disclose all matters
in internal control that might be material weaknesses under standards
established by the American Institute of Certified Public Accountants. A
material weakness is a condition in which the design or operation of one or more
of the internal control components does not reduce to a relatively low level the
risk that misstatements caused by error or fraud in amounts that would be
material in relation to the financial statements being audited may occur and not
be detected within a timely period by employees in the normal course of
performing their assigned functions. However, we noted no matters involving
internal control and its operation, including controls for safeguarding
securities, that we consider to be material weaknesses as defined above as of
March 31, 2002.

This report is intended solely for the information and use of the Board of
Directors, management 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

PricewaterhouseCoopers LLP

Denver, Colorado
May 15, 2002

EX-99.77.D

                                                                   Exhibit 77(d)


                POLICIES WITH RESPECT TO SECURITIES INVESTMENTS

On February 26, 2002, the Board of Directors of the Registrant adopted, on
behalf of the Fund, and in accordance with the requirements of Rule 35d-1 of the
Investment Company Act of 1940, an investment policy to invest at least 80% of
the Fund's assets in the type of investment suggested by its name, and to give
shareholders 60 days' prior notice before any change in the Fund's 80%
investment strategy is implemented.

EX-99.77.Q.1

                                                                Exhibit 77(q)(1)

                                    EXHIBITS

(a) Form of Articles of Amendment to the Registrant's Articles of Incorporation
changing the (1) Registrant's name from Pilgrim Investment Funds, Inc. to "ING
Investment Funds, Inc." and (2) Fund's name from Pilgrim High Yield Fund to "ING
High Yield Fund" - filed as an exhibit to Post-Effective Amendment No. 53 to the
Registrant's Form N-1A Registration Statement on February 27, 2002 and
incorporated herein by reference.

(b) The text of the Fund's new investment policy complying with Rule 35d-1 is
incorporated by reference to the Fund's Prospectus and Statement of Additional
Information, both dated March 1, 2002 and both filed in Post-Effective Amendment
No. 53 to the Registrant's Form N-1A Registration Statement on February 27,
2002.