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 ING High  Yield  Opportunity  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 ING High Yield Opportunity 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 80% investment policy is implemented.