Exhibit 77(d)

                  POLICIES WITH RESPECT TO SECURITY INVESTMENTS

Effective November 16, 2000, the Fund revised its principal  investment strategy
to read as follows:

     The  Fund  normally  invests  at  least  65% of its net  assets  in  equity
     securities of large U.S. companies that the portfolio managers believe have
     above-average prospects for growth. The equity securities in which the Fund
     may invest include common and preferred  stock,  warrants,  and convertible
     securities.  The  Fund  considers  a  company  to be  large  if its  market
     capitalization  corresponds at the time of purchase to the upper 90% of the
     S&P 500 Index. As of October 19th, 2000, this meant market  capitalizations
     in the range of $10 billion to $571 billion. Capitalization of companies in
     the S&P 500 Index will change with market conditions.

     The  portfolio  managers  emphasize  a growth  approach  by  searching  for
     companies that they believe are managing change  advantageously  and may be
     poised to exceed growth expectations.  The portfolio managers focus on both
     a  "bottom-up"   analysis  that  evaluates  the  financial   condition  and
     competitiveness of individual  companies and a "top-down" thematic approach
     and a sell discipline.  The portfolio managers seek to identify themes that
     reflect  the major  social,  economic  and  technological  trends that they
     believe are likely to shape the future of business  and  commerce  over the
     next three to five years,  and seek to provide a framework for  identifying
     the industries and companies they believe may benefit most. This "top-down"
     approach is combined  with  rigorous  fundamental  research (a  "bottom-up"
     approach) to guide stock selection and portfolio structure.