Exhibit 77(k)

On February 26, 2001, the Board of Trustees,  and Audit  Committee  thereof,  of
Pilgrim Advisory Funds, Inc., on behalf of Pilgrim Asia-Pacific Equity Fund (the
"Fund"),  approved  replacing  KPGM LLP with  PricewaterhouseCoopers  LLP as the
Fund's  certifying  accountant.   The  change  was  part  of  standardizing  the
accountancy  process to ensure that the International  Funds in the Pilgrim Fund
complex shared the same independent accountant. KPMG LLP did not in the past two
years  issue a  principal  accountant's  report  that (i)  contained  an adverse
opinion or a  disclaimer  of opinion,  or (ii) was  qualified  or modified as to
uncertainty,  audit scope, or accounting  principles.  Also, during the past two
years,  the  Fund  had no  disagreements  with  KPMG  LLP  regarding  accounting
principles or practices,  financial statement  disclosure,  or auditing scope or
procedure.