ING PILGRIM SENIOR INCOME FUND
N-8A, 2000-12-15
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                       SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                    FORM N-8A

                          NOTIFICATION OF REGISTRATION
                      FILED PURSUANT TO SECTION 8(a) OF THE
                         INVESTMENT COMPANY ACT OF 1940


     The  undersigned  investment  company  hereby  notifies the  Securities and
Exchange  Commission  that it registers  under and pursuant to the provisions of
Section 8(a) of the Investment  Company Act of 1940 and in connection  with such
notification    of    registration    submits   the    following    information:

                              --------------------

                      Name: ING Pilgrim Senior Income Fund


                         7337 East Doubletree Ranch Road
                              Scottsdale, AZ 85258
                      Address of Principal Business Office
                     (No. & Street, City, State, Zip Code):


             Telephone Number (including area code): (480) 477-3000


                Name and address of agent for service of process:

                             James M. Hennessy, Esq.
                             ING Pilgrim Group, Inc.
                         7337 East Doubletree Ranch Road
                              Scottsdale, AZ 85258

                                   Copies to:

Jeffrey S. Puretz, Esq.                               Margaret A. Bancroft, Esq.
        Dechert                                                 Dechert
 1775 Eye Street, N.W.                                   30 Rockefeller Plaza
 Washington, DC 20006                                     New York, NY 10112

                             Check Appropriate Box:

Registrant is filing a  Registration  Statement  pursuant to Section 8(b) of the
Investment  Company Act of 1940  concurrently  with the filing of Form N-8A:
YES [ ]  NO [X]
<PAGE>
Item 1. ING Pilgrim Senior Income Fund (the "Fund")

Item 2. The Fund was organized in Delaware on December 15, 2000.

Item 3. Delaware Business Trust

Item 4. Management Company

Item 5. (a) Closed-end

        (b) Diversified

Item 6. ING Pilgrim Investments, Inc., 7337 East Doubletree Ranch Road,
        Scottsdale, Arizona 85258

Item 7. James M. Hennessy President, Secretary and Trustee
        Daniel A. Norman Treasurer and Trustee

        The address of all above-mentioned officers or trustees is
        7337 East Doubletree Ranch Road, Scottsdale, Arizona 85258.

Item 8. Not Applicable

Item 9. (a) No

        (b) Not Applicable

        (c)  It is anticipated that the registrant will make a public offering
             of its securities upon effectiveness of a Registration  Statement
             to be filed on Form N-2.

        (d) No

        (e) Not Applicable

Item 10. Zero ($0)

Item 11. No

Item 12. Not Applicable
<PAGE>
                                   SIGNATURES

     Pursuant to the  requirements  of the  Investment  Company Act of 1940, the
Registrant has caused this notification of registration to be duly signed on its
behalf  in the  city of  Scottsdale  and  State  of  Arizona  on the 15th day of
December, 2000.


                                         ING PILGRIM SENIOR INCOME FUND


                                         By: /s/ James M. Hennessy
                                            -------------------------
                                             James M. Hennessy
                                             President and Secretary

Attest: /s/ Daniel A. Norman
       ----------------------------
       Daniel A. Norman
       Treasurer


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