Exhibit 12(B)


                            [LETTERHEAD OF DECHERT]


                                  May 29, 2001


Pilgrim Advisory Funds, Inc.
7337 East Doubletree Ranch Road
Scottsdale, Arizona  85258-2034

     Re: Pilgrim Advisory Funds, Inc.
         (File No. 333-51722)


Dear Sirs:

     We hereby  consent to the  incorporation  by reference to our opinion as an
exhibit to  Post-Effective  Amendment  No. 2 to the  Registration  Statement  of
Pilgrim  Advisory  Funds,  Inc., 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