Exhibit 77(d)


                 POLICIES WITH RESPECT TO SECURITY INVESTMENTS

On May 9, 2001, the Board of Trustees of the Registrant approved changes to the
Pilgrim Money Market Fund's investment policies to reflect the termination of
the Pilgrim Money Market Fund's master-feeder arrangement with the Reserve
Institutional Trust. Effective May 21, 2001, the following disclosure reflects
the Pilgrim Money Market Fund's revised investment policies (for purposes of
this disclosure, the Pilgrim Money Market Fund is referred to as the "Fund"):

     The Fund will invest in short-term money market instruments that have been
     rated in one of the two highest rating categories by both Standard & Poor's
     ("S&P") and Moody's Investor Service, Inc. ("Moody's"), both major rating
     agencies. The Fund invests in short-term money market instruments (those
     with a remaining maturity of 397 days or less) that offer attractive yields
     and are considered to be undervalued relative to issues of similar credit
     quality and interest rate sensitivity.

     Specifically, the Fund will invest in instruments issued by the U.S.
     Government, its agencies and instrumentalities (U.S. Government
     Securities); high quality deposit-type obligations, such as negotiable
     certificates of deposit and time deposits, banker's acceptances and letters
     of credit of domestic and foreign banks and foreign branches of foreign
     banks; savings and loans associations and savings banks; other short-term
     instruments of similar quality; instruments fully collateralized by such
     obligations; and repurchase agreements under which the Fund may acquire an
     underlying debt instrument for a relatively short period subject to the
     obligations of the sellers to repurchase, and of the Fund to resell, at a
     fixed price.

     The Fund will also ensure that its money market instruments' average
weighted maturities do not exceed 90 days.