CALVERT IMPACT FUND INC
N-14/A, EX-11, 2000-09-28
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EDGAR  EXHIBIT  11

September  27,  2000


Securities  and  Exchange  Commission
Judiciary  Plaza
450  Fifth  Street,  N.W.
Washington,  D.C.  20549

Re:  Exhibit  11
Calvert  Impact  Fund,  Inc.
File  Numbers  811-10045,  333-44064


Ladies  and  Gentlemen:

As  counsel  to  Calvert  Impact  Fund,  Inc.,  it  is my opinion, based upon an
examination  of  the  articles  of  incorporation,  amendments, restatements and
by-laws  and  such  other  original  or  photostatic  copies  of  fund  records,
certificates  of  public officials, documents, papers, statutes, and authorities
as  I  deemed  necessary  to form the basis of this opinion, that the securities
being  registered  by  this  Pre-Effective  Amendment  No. 3 will, when sold, be
legally  issued,  fully  paid  and  non-assessable.

Consent  is hereby given to file this Opinion of Counsel with the Securities and
Exchange Commission as an exhibit to the Fund's Pre-Effective Amendment No. 3 to
the  Form  N-14.


Sincerely,

/s/  Ivy  Wafford  Duke
Ivy  Wafford  Duke
Associate  General  Counsel






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