Exhibit 77(q)(1)

(e)(1) Form of Investment  Management  Agreement between Pilgrim Advisory Funds,
Inc.,  on behalf of the Fund,  and ING  Pilgrim  Investment,  Inc. - filed as an
exhibit  to  Post-Effective  Amendment  No.  15 to the  Registrant's  Form  N-1A
Registration   Statement  on  December  22,  2000  and  incorporated  herein  by
reference.

(g)(1) Form of Agreement and Plan of  Reorganization  between  Pilgrim  SmallCap
Asia Growth Fund and Pilgrim  Advisory  Funds,  Inc.,  on behalf of the Fund, is
incorporated by reference to the Registration Statement on Form N-14 as filed on
December 13, 2000.