Exhibit 77(m)

(a) The Board of Trustees of Pilgrim  SmallCap Asia Growth Fund, (on November 2,
2000) and Shareholders of Pilgrim SmallCap Asia Growth Fund (on March 15, 2001),
and the Board of Directors of Pilgrim  Advisory  Funds,  Inc.,  on behalf of the
Fund (on  November 2, 2000)  approved an  Agreement  and Plan of  Reorganization
under  which the Fund  acquired  all of the  assets and  liabilities  of Pilgrim
SmallCap  Asia  Growth Fund in  exchange  for  Classes A and Class B shares,  as
applicable, of the Fund. The reorganization concluded on March 23, 2001.