Exhibit 77(k)(f)

July 11, 2001

Securities and Exchange Commission
Washington, DC  20549
Ladies and Gentlemen:

We were previously principal accountants for the Pilgrim Asia Pacific Equity
Fund (the "Fund") and, under the date of August 4, 2000, we reported on the
statement of assets and liabilities, including the portfolio of investments, of
the Fund as of June 30, 2000 and the related statement of operations for the
year then ended, the statement of changes in net assets for each of the years in
the two-year period then ended, and the financial highlights for each of the
years in the four-year period then ended and the period from September 1, 1995
(commencement of operations) to June 30, 1996. On November 2, 2000, our
appointment as principal accountants was terminated. We have read the Fund's
statements included under Item 77k of its Form N-SAR dated July 11, 2001, and we
agree with such statements.


                                        Very truly yours,


                                        /s/ KPMG LLP