<PAGE> PAGE 1
000 B000000 06/30/95
000 C000000 0000355348
000 D000000 N
000 E000000 NF
000 F000000 Y
000 G000000 N
000 H000000 N
000 I000000 3.0.a
000 J000000 A
001 A000000 COMMAND TAX-FREE FUND
001 B000000 811-3252
001 C000000 2122141250
002 A000000 199 WATER STREET
002 B000000 NEW YORK
002 C000000 NY
002 D010000 10292
003 000000 N
004 000000 N
005 000000 N
006 000000 N
007 A000000 N
007 B000000 0
007 C010100 1
007 C010200 2
007 C010300 3
007 C010400 4
007 C010500 5
007 C010600 6
007 C010700 7
007 C010800 8
007 C010900 9
007 C011000 10
008 A000001 PRUDENTIAL MUTUAL FUND MANAGEMENT, INC.
008 B000001 A
008 C000001 801-31104
008 D010001 NEW YORK
008 D020001 NY
008 D030001 10292
008 A000002 THE PRUDENTIAL INVESTMENT CORPORATION
008 B000002 S
008 C000002 801-22808
008 D010002 NEWARK
008 D020002 NJ
008 D030002 07101
011 A000001 PRUDENTIAL MUTUAL FUND DISTRIBUTORS, INC.
011 B000001 8-38739
011 C010001 NEW YORK
011 C020001 NY
011 C030001 10292
011 A000002 PRUDENTIAL SECURITIES INCORPORATED
011 B000002 8-27154
<PAGE> PAGE 2
011 C010002 NEW YORK
011 C020002 NY
011 C030002 10292
012 A000001 PRUDENTIAL MUTUAL FUND SERVICES,INC.
012 B000001 84-4110019
012 C010001 NEW BRUNSWICK
012 C020001 NJ
012 C030001 08906
013 A000001 PRICE WATERHOUSE LLP
013 B010001 NEW YORK
013 B020001 NY
013 B030001 10036
014 A000001 PRUDENTIAL SECURITIES INCORPORATED
014 B000001 8-27154
014 A000002 PRUCO SECURITIES CORPORATION
014 B000002 8-16402
014 A000003 PRUDENTIAL MUTUAL FUND DISTRIBUTORS, INC.
014 B000003 8-38739
015 A000001 STATE STREET BANK AND TRUST COMPANY
015 B000001 C
015 C010001 NORTH QUINCY
015 C020001 MA
015 C030001 02171
015 E010001 X
018 000000 Y
019 A000000 Y
019 B000000 70
019 C000000 PRUDENTIAL
020 C000001 0
020 C000002 0
020 C000003 0
020 C000004 0
020 C000005 0
020 C000006 0
020 C000007 0
020 C000008 0
020 C000009 0
020 C000010 0
021 000000 0
022 A000001 SMITH BARNEY, INC.
022 B000001 13-1912900
022 C000001 482898
022 D000001 152515
022 A000002 GOLDMAN, SACHS & CO.
022 B000002 13-5108880
022 C000002 323180
022 D000002 234900
022 A000003 MORGAN (J.P.) SECURITIES, INC.
022 B000003 13-3224016
022 C000003 259640
022 D000003 154365
<PAGE> PAGE 3
022 A000004 CS FIRST BOSTON CORP.
022 B000004 13-5659485
022 C000004 230935
022 D000004 131828
022 A000005 DONALDSON, LUFKIN & JENRETTE SECURITIES CORP.
022 B000005 13-2741729
022 C000005 135400
022 D000005 59000
022 A000006 LEHMAN, INC.
022 B000006 13-2518466
022 C000006 147100
022 D000006 20400
022 A000007 CHEMICAL BANKING CORP.
022 B000007 13-5227302
022 C000007 86100
022 D000007 78300
022 A000008 MERRILL, LYNCH, PIERCE, FENNER, & SMITH, INC.
022 B000008 13-5674085
022 C000008 81090
022 D000008 32820
022 A000009 CITICORP SECURITIES, INC.
022 C000009 65560
022 D000009 39595
022 A000010 DOUGHERTY, DAWKINS, STRAND & BIGELOW INC.
022 B000010 41-1300840
022 C000010 94890
022 D000010 10000
023 C000000 2458527
023 D000000 1261543
024 000000 N
025 D000001 0
025 D000002 0
025 D000003 0
025 D000004 0
025 D000005 0
025 D000006 0
025 D000007 0
025 D000008 0
026 A000000 N
026 B000000 N
026 C000000 N
026 D000000 Y
026 E000000 N
026 F000000 N
026 G010000 N
026 G020000 N
026 H000000 N
027 000000 Y
028 A010000 566743
028 A020000 2091
028 A030000 0
<PAGE> PAGE 4
028 A040000 368700
028 B010000 321200
028 B020000 2487
028 B030000 0
028 B040000 311919
028 C010000 340351
028 C020000 2879
028 C030000 0
028 C040000 330730
028 D010000 372673
028 D020000 2677
028 D030000 0
028 D040000 361193
028 E010000 389367
028 E020000 3151
028 E030000 0
028 E040000 349832
028 F010000 406710
028 F020000 2811
028 F030000 0
028 F040000 369792
028 G010000 2397044
028 G020000 16096
028 G030000 0
028 G040000 2092166
028 H000000 0
029 000000 N
030 A000000 0
030 B000000 0.00
030 C000000 0.00
031 A000000 0
031 B000000 0
032 000000 0
033 000000 0
034 000000 N
035 000000 0
036 B000000 0
037 000000 N
038 000000 0
039 000000 Y
040 000000 Y
041 000000 Y
042 A000000 0
042 B000000 0
042 C000000 0
042 D000000 100
042 E000000 0
042 F000000 0
042 G000000 0
042 H000000 0
043 000000 1159
<PAGE> PAGE 5
044 000000 0
045 000000 Y
046 000000 N
047 000000 Y
048 000000 0.000
048 A010000 500000
048 A020000 0.500
048 B010000 500000
048 B020000 0.425
048 C010000 0
048 C020000 0.000
048 D010000 0
048 D020000 0.000
048 E010000 0
048 E020000 0.000
048 F010000 0
048 F020000 0.000
048 G010000 0
048 G020000 0.000
048 H010000 0
048 H020000 0.000
048 I010000 0
048 I020000 0.000
048 J010000 0
048 J020000 0.000
048 K010000 1000000
048 K020000 0.375
049 000000 N
050 000000 N
051 000000 N
052 000000 N
053 A000000 N
054 A000000 Y
054 B000000 Y
054 C000000 N
054 D000000 N
054 E000000 N
054 F000000 N
054 G000000 N
054 H000000 Y
054 I000000 N
054 J000000 Y
054 K000000 N
054 L000000 N
054 M000000 N
054 N000000 N
054 O000000 N
055 A000000 Y
055 B000000 N
056 000000 Y
057 000000 N
<PAGE> PAGE 6
058 A000000 N
059 000000 Y
060 A000000 Y
060 B000000 Y
061 000000 10000
062 A000000 Y
062 B000000 0.0
062 C000000 0.0
062 D000000 0.0
062 E000000 99.3
062 F000000 0.0
062 G000000 0.0
062 H000000 0.0
062 I000000 0.0
062 J000000 0.0
062 K000000 0.0
062 L000000 0.0
062 M000000 0.0
062 N000000 0.0
062 O000000 0.0
062 P000000 0.0
062 Q000000 0.0
062 R000000 0.0
063 A000000 54
063 B000000 0.0
064 A000000 N
064 B000000 N
066 A000000 N
067 000000 N
068 A000000 N
068 B000000 N
069 000000 N
070 A010000 N
070 A020000 N
070 B010000 N
070 B020000 N
070 C010000 N
070 C020000 N
070 D010000 N
070 D020000 N
070 E010000 N
070 E020000 N
070 F010000 N
070 F020000 N
070 G010000 N
070 G020000 N
070 H010000 N
070 H020000 N
070 I010000 N
070 I020000 N
070 J010000 Y
<PAGE> PAGE 7
070 J020000 Y
070 K010000 N
070 K020000 N
070 L010000 N
070 L020000 N
070 M010000 N
070 M020000 N
070 N010000 N
070 N020000 N
070 O010000 Y
070 O020000 Y
070 P010000 Y
070 P020000 Y
070 Q010000 N
070 Q020000 N
070 R010000 N
070 R020000 N
071 A000000 0
071 B000000 0
071 C000000 0
071 D000000 0
072 A000000 12
072 B000000 34377
072 C000000 0
072 D000000 0
072 E000000 0
072 F000000 4314
072 G000000 0
072 H000000 0
072 I000000 184
072 J000000 205
072 K000000 0
072 L000000 40
072 M000000 56
072 N000000 70
072 O000000 0
072 P000000 0
072 Q000000 0
072 R000000 41
072 S000000 20
072 T000000 1159
072 U000000 0
072 V000000 0
072 W000000 40
072 X000000 6129
072 Y000000 0
072 Z000000 28249
072AA000000 0
072BB000000 0
072CC010000 0
072CC020000 0
<PAGE> PAGE 8
072DD010000 28249
072DD020000 0
072EE000000 0
073 A010000 0.0320
073 A020000 0.0000
073 B000000 0.0000
073 C000000 0.0000
074 A000000 21
074 B000000 0
074 C000000 1048290
074 D000000 0
074 E000000 0
074 F000000 0
074 G000000 0
074 H000000 0
074 I000000 0
074 J000000 13500
074 K000000 0
074 L000000 34512
074 M000000 30
074 N000000 1096353
074 O000000 22790
074 P000000 455
074 Q000000 0
074 R010000 0
074 R020000 0
074 R030000 0
074 R040000 17540
074 S000000 0
074 T000000 1055568
074 U010000 1055568
074 U020000 0
074 V010000 1.00
074 V020000 0.00
074 W000000 1.0002
074 X000000 16816
074 Y000000 0
075 A000000 926888
075 B000000 0
076 000000 0.00
077 A000000 Y
077 B000000 Y
077 C000000 N
077 D000000 N
077 E000000 N
077 F000000 N
077 G000000 N
077 H000000 N
077 I000000 N
077 J000000 N
077 K000000 N
<PAGE> PAGE 9
077 L000000 N
077 M000000 N
077 N000000 N
077 O000000 N
077 P000000 N
078 000000 N
080 A000000 ICI MUTUAL INSURANCE COMPANY
080 C000000 65000
081 A000000 Y
081 B000000 84
082 A000000 N
082 B000000 0
083 A000000 N
083 B000000 0
084 A000000 N
084 B000000 0
085 A000000 Y
085 B000000 N
086 A010000 0
086 A020000 0
086 B010000 0
086 B020000 0
086 C010000 0
086 C020000 0
086 D010000 0
086 D020000 0
086 E010000 0
086 E020000 0
086 F010000 0
086 F020000 0
SIGNATURE GRACE TORRES
TITLE TREASURER
<TABLE> <S> <C>
<ARTICLE> 6
<CIK> 0000355348
<NAME> COMMAND TAX-FREE FUND
<S> <C>
<PERIOD-TYPE> 6-MOS
<FISCAL-YEAR-END> JUN-30-1995
<PERIOD-END> JUN-30-1995
<INVESTMENTS-AT-COST> 0
<INVESTMENTS-AT-VALUE> 1,048,290,094
<RECEIVABLES> 48,012,329
<ASSETS-OTHER> 50,098
<OTHER-ITEMS-ASSETS> 0
<TOTAL-ASSETS> 1,096,352,521
<PAYABLE-FOR-SECURITIES> 22,789,937
<SENIOR-LONG-TERM-DEBT> 0
<OTHER-ITEMS-LIABILITIES> 17,994,938
<TOTAL-LIABILITIES> 40,784,875
<SENIOR-EQUITY> 0
<PAID-IN-CAPITAL-COMMON> 1,055,567,646
<SHARES-COMMON-STOCK> 1,055,567,646
<SHARES-COMMON-PRIOR> 847,601,743
<ACCUMULATED-NII-CURRENT> 0
<OVERDISTRIBUTION-NII> 0
<ACCUMULATED-NET-GAINS> 0
<OVERDISTRIBUTION-GAINS> 0
<ACCUM-APPREC-OR-DEPREC> 0
<NET-ASSETS> 1,055,567,646
<DIVIDEND-INCOME> 0
<INTEREST-INCOME> 34,377,013
<OTHER-INCOME> 0
<EXPENSES-NET> 6,128,541
<NET-INVESTMENT-INCOME> 28,248,472
<REALIZED-GAINS-CURRENT> 45
<APPREC-INCREASE-CURRENT> 0
<NET-CHANGE-FROM-OPS> 28,248,517
<EQUALIZATION> 0
<DISTRIBUTIONS-OF-INCOME> 0
<DISTRIBUTIONS-OF-GAINS> 0
<DISTRIBUTIONS-OTHER> (28,248,517)
<NUMBER-OF-SHARES-SOLD> 4,346,712,584
<NUMBER-OF-SHARES-REDEEMED> (4,166,995,198)
<SHARES-REINVESTED> 28,248,517
<NET-CHANGE-IN-ASSETS> 207,965,903
<ACCUMULATED-NII-PRIOR> 0
<ACCUMULATED-GAINS-PRIOR> 0
<OVERDISTRIB-NII-PRIOR> 0
<OVERDIST-NET-GAINS-PRIOR> 0
<GROSS-ADVISORY-FEES> 4,314,275
<INTEREST-EXPENSE> 0
<GROSS-EXPENSE> 6,128,541
<AVERAGE-NET-ASSETS> 926,888,000
<PER-SHARE-NAV-BEGIN> 1.00
<PER-SHARE-NII> 0.03
<PER-SHARE-GAIN-APPREC> 0.00
<PER-SHARE-DIVIDEND> 0.00
<PER-SHARE-DISTRIBUTIONS> (0.03)
<RETURNS-OF-CAPITAL> 0.00
<PER-SHARE-NAV-END> 1.00
<EXPENSE-RATIO> 0.66
<AVG-DEBT-OUTSTANDING> 0
<AVG-DEBT-PER-SHARE> 0.00
</TABLE>
REMEMBER THIS DOC. MUST FIT ON ONE PAGE.
BE SURE TO ALTER YOUR FOOTERAugust 21, 1995
To the Trustees of
Command Government Fund
In planning and performing our audit of the financial statements of Command
Government Fund (the "Fund") for the year ended June 30, 1995, we considered its
internal control structure, including procedures for safeguarding securities, in
order to determine our auditing procedures for the purposes of expressing our
opinion on the financial statements and to comply with the requirements of Form
N-SAR, and not to provide assurance on the internal control structure.
The management of the Fund is responsible for establishing and maintaining an
internal control structure. In fulfilling this responsibility, estimates and
judgments by management are required to assess the expected benefits and related
costs of internal control structure policies and procedures. Two of the
objectives of an internal control structure are to provide management with
reasonable, but not absolute, assurance that assets are appropriately
safeguarded against loss from unauthorized use or disposition and that
transactions are executed in accordance with management's authorization and
recorded properly to permit preparation of financial statements in conformity
with generally accepted accounting principles.
Because of inherent limitations in any internal control structure, errors or
irregularities may occur and may not be detected. Also, projection of any
evaluation of the structure to future periods is subject to the risk that it may
become inadequate because of changes in conditions or that the effectiveness of
the design and operation may deteriorate.
Our consideration of the internal control structure would not necessarily
disclose all matters in the internal control structure that might be material
weaknesses under standards established by the American Institute of Certified
Public Accountants. A material weakness is a condition in which the design or
operation of the specific internal control structure elements does not reduce to
a relatively low level the risk that errors or irregularities in amounts that
would be material in relation to the financial statements being audited may
occur and not be detected within a timely period by employees in the normal
course of performing their assigned functions. However, we noted no matters
involving the internal control structure, including procedures for safeguarding
securities, that we consider to be material weaknesses as defined above as of
June 30, 1995.
This report is intended solely for the information and use of management and the
Securities and Exchange Commission.
PRICE WATERHOUSE LLP
August 21, 1995
To the Trustees of
Command Money Fund
In planning and performing our audit of the financial statements of Command
Money Fund (the "Fund") for the year ended June 30, 1995, we considered its
internal control structure, including procedures for safeguarding securities, in
order to determine our auditing procedures for the purposes of expressing our
opinion on the financial statements and to comply with the requirements of Form
N-SAR, and not to provide assurance on the internal control structure.
The management of the Fund is responsible for establishing and maintaining an
internal control structure. In fulfilling this responsibility, estimates and
judgments by management are required to assess the expected benefits and related
costs of internal control structure policies and procedures. Two of the
objectives of an internal control structure are to provide management with
reasonable, but not absolute, assurance that assets are appropriately
safeguarded against loss from unauthorized use or disposition and that
transactions are executed in accordance with management's authorization and
recorded properly to permit preparation of financial statements in conformity
with generally accepted accounting principles.
Because of inherent limitations in any internal control structure, errors or
irregularities may occur and may not be detected. Also, projection of any
evaluation of the structure to future periods is subject to the risk that it may
become inadequate because of changes in conditions or that the effectiveness of
the design and operation may deteriorate.
Our consideration of the internal control structure would not necessarily
disclose all matters in the internal control structure that might be material
weaknesses under standards established by the American Institute of Certified
Public Accountants. A material weakness is a condition in which the design or
operation of the specific internal control structure elements does not reduce to
a relatively low level the risk that errors or irregularities in amounts that
would be material in relation to the financial statements being audited may
occur and not be detected within a timely period by employees in the normal
course of performing their assigned functions. However, we noted no matters
involving the internal control structure, including procedures for safeguarding
securities, that we consider to be material weaknesses as defined above as of
June 30, 1995.
This report is intended solely for the information and use of management and the
Securities and Exchange Commission.
PRICE WATERHOUSE LLP
August 21, 1995
To the Trustees of
Command Tax-Free Fund
In planning and performing our audit of the financial statements of Command Tax-
Free Fund (the "Fund") for the year ended June 30, 1995, we considered its
internal control structure, including procedures for safeguarding securities, in
order to determine our auditing procedures for the purposes of expressing our
opinion on the financial statements and to comply with the requirements of Form
N-SAR, and not to provide assurance on the internal control structure.
The management of the Fund is responsible for establishing and maintaining an
internal control structure. In fulfilling this responsibility, estimates and
judgments by management are required to assess the expected benefits and related
costs of internal control structure policies and procedures. Two of the
objectives of an internal control structure are to provide management with
reasonable, but not absolute, assurance that assets are appropriately
safeguarded against loss from unauthorized use or disposition and that
transactions are executed in accordance with management's authorization and
recorded properly to permit preparation of financial statements in conformity
with generally accepted accounting principles.
Because of inherent limitations in any internal control structure, errors or
irregularities may occur and may not be detected. Also, projection of any
evaluation of the structure to future periods is subject to the risk that it may
become inadequate because of changes in conditions or that the effectiveness of
the design and operation may deteriorate.
Our consideration of the internal control structure would not necessarily
disclose all matters in the internal control structure that might be material
weaknesses under standards established by the American Institute of Certified
Public Accountants. A material weakness is a condition in which the design or
operation of the specific internal control structure elements does not reduce to
a relatively low level the risk that errors or irregularities in amounts that
would be material in relation to the financial statements being audited may
occur and not be detected within a timely period by employees in the normal
course of performing their assigned functions. However, we noted no matters
involving the internal control structure, including procedures for safeguarding
securities, that we consider to be material weaknesses as defined above as of
June 30, 1995.
This report is intended solely for the information and use of management and the
Securities and Exchange Commission.
PRICE WATERHOUSE LLP
- 2 -
DUAL_ABC.DOC - Windows - 08/29/95
Board of Directors or Trustees of:
Prudential Adjustable Rate Securities Fund
Prudential IncomeVertible Fund
The BlackRock Government Income Trust
Prudential Intermediate Global Income Fund
Prudential California Municipal Fund (2 Portfolios)
Prudential Multi-Sector Fund
Prudential Equity Fund
Prudential Municipal Bond Fund (3 Portfolios)
Prudential Equity Income Fund
Prudential Municipal Series Fund (12 Portfolios)
Prudential FlexiFund (2 Portfolios)
Prudential National Municipals Fund
Prudential GNMA Fund
Prudential Pacific Growth Fund
Prudential Global Fund
Prudential Short-Term Global Income Fund (2 Portfolios)
Prudential Global Genesis Fund
Prudential Structured Maturity Fund
Prudential Global Natural Resources Fund
Prudential U.S. Government Fund
Prudential Government Plus Fund
Prudential Utility Fund
Prudential Growth Fund
Global Utility Fund, Inc.
Prudential Growth Opportunity Fund
Nicholas-Applegate Fund, Inc.
Prudential High Yield Fund
We have examined the accompanying description of the Prudential Dual
Pricing Worksheet (the "Worksheet") application of State Street Bank
and Trust Company ("State Street"), custodian and recordkeeper for
the Prudential Mutual Funds (the "Funds"). Our examination included
procedures to obtain reasonable assurance about whether (1) the
accompanying description presents fairly, in all material respects,
the aspects of State Street's policies and procedures that may be
relevant to a Fund's internal control structure relating to the
Worksheet, (2) the control structure policies and procedures included
in the description were suitably designed to achieve the control
objectives specified in the description, if those policies and
procedures were complied with satisfactorily, and (3) such policies
and procedures had been placed in operation as of June 30, 1994. The
control objectives were specified by Prudential Mutual Fund
Management. Our examination was performed in accordance with
standards established by the American Institute of Certified Public
Accountants and included those procedures we considered necessary in
the circumstances to obtain a reasonable basis for rendering our
opinion.
In our opinion, the accompanying description of the aforementioned
application presents fairly, in all material respects, the relevant
aspects of State Street's policies and procedures that had been
placed in operation as of June 30, 1994. Also, in our opinion, the
policies and procedures, as described, are suitably designed to
provide reasonable assurance that the specified control objectives
would be achieved if the described policies and procedures were
complied with satisfactorily.
In addition to the procedures we considered necessary to render our
opinion as expressed in the previous paragraph, we applied tests to
specific policies and procedures, listed in Section I, to obtain
evidence about their effectiveness in meeting the control objectives,
described in Section I during the period from July 1, 1993 to
June 30, 1994. The nature, timing, extent, and results of the tests
are listed in Section II. In our opinion the policies and procedures
that were tested, as described in Section II, were operating with
sufficient effectiveness to provide reasonable, but not absolute,
assurance that the control objectives specified in Section I were
achieved during the period from July 1, 1993 to June 30, 1994.
The relative effectiveness and significance of specific policies and
procedures at State Street, and their effect on assessments of
control risk on the Funds are dependent on their interaction with the
policies, procedures, and other factors present at individual Funds.
We have performed no procedures to evaluate the effectiveness of
policies and procedures at individual Funds in connection with this
report.
The description of policies and procedures at State Street is as of
June 30, 1994, and information about tests of the operating
effectiveness of specified policies and procedures covers the period
from July 1, 1993 to June 30, 1994. Any projection of such
information to the future is subject to the risk that, because of
change, the description may no longer portray the system in
existence. The potential effectiveness of specified policies and
procedures at State Street is subject to inherent limitations and,
accordingly, errors or irregularities may occur and not be detected.
Furthermore, the projection of any conclusions, based on our
findings, to future periods is subject to the risk that changes may
alter the validity of such conclusions.
This report is intended solely for use by the management and Boards
of Directors/Trustees of the Funds, the independent auditors of the
Funds and the Securities and Exchange Commission.
July 28, 1994
SECTION I
Policies and Procedures Placed in Operation
Prudential Dual Pricing Worksheet
Effective January 22, 1990, the Funds, offered by Prudential
Securities Incorporated (formerly Prudential-Bache Securities,
Inc.) and Prudential Mutual Fund Distributors, Inc., adopted a dual
pricing system. The dual pricing system consists of two classes of
shares (Class A and Class B for all funds except the Florida Series
of Prudential Municipal Series Fund. This Fund offers Class A and
Class D shares.) for the Funds. The Class A shares are subject to
a front-end sales load and the Class B and Class D shares are
subject to a contingent deferred sales charge. Each of the classes
of shares represent interests in the same portfolio of investments
of the respective Fund and are identical in all respects, except
that each class is subject to different distribution expenses and
has exclusive voting rights with respect to the Rule 12b-1
distribution plan pursuant to which such distribution expenses are
paid.
In order to allocate income and expenses between the two classes of
shares, State Street Bank and Trust Company (the Funds' custodian
and recordkeeper) utilizes the Prudential Dual Pricing Worksheet
(the "Worksheet") (see Exhibit I). The Worksheet is a manual
supplementary application that extracts relevant data from the
Funds' primary accounting system, allocates income and expenses
between the two classes of shares and computes the daily net asset
value and, if applicable, the dividend/distribution for each class
of shares. Internal accounting controls that are relevant to the
Fund can be divided into two components - controls related to the
mutual fund accounting system resident at State Street Bank and
Trust Company (the "primary accounting system") and controls
related to the Worksheet.
The spcific control objectives and policies and procedures relating
to the Worksheet are described on pages 4, 5 and 6. A description
of the tests of the policies and procedures designed to obtain
evidence about the operating effectiveness of those policies and
procedures in achieving the specific control objectives is included
in Section II.
Control Objectives and Policies and Procedures
Prudential Dual Pricing Worksheet
The Worksheet is a supplementary manual application to the Funds'
primary accounting system. Certain data is extracted from the
primary accounting system to allocate income and expenses and to
calculate the daily net asset value and, if applicable,
dividends/distributions for each class of shares. The primary
accounting system includes the details of transactions in
accordance with the Investment Company Act of 1940, as amended.
The following represents the internal accounting control objectives
and policies and procedures for the allocation of income and
expenses and the computation of the net asset value and, if
applicable, the dividend/distribution for each class of shares
utilizing the Worksheet. It does not cover the internal accounting
control policies and procedures surrounding the processing of
information into the Funds' primary accounting system.
CONTROL POLICIES
CONTROL OBJECTIVES AND PROCEDURES
A. Capital share activity as
reported
by the 1. Daily, the transfer
agent forwards reports of Fund's
transfer agent is recorded for each capital share activity for
each class which
class in an accurate and timely manner by includes a
summary of subscriptions,
the Fund. redemptions, exchanges and
other
information (the
"Supersheet"). The
opening day's balance for
shares outstanding
and current day activity is
recorded
on the Worksheet.
2. Estimated interim
share activity for the
current day not recorded in
the Supersheet is received
via telefax from the
transfer agent and is
recorded for each class on
the Worksheet.
3. A report of
outstanding shares eligible
for dividends is received
from the transfer agent and
is recorded for each class
on the Worksheet.
B. Net Asset Value ("NAV")
and, if applicable, 1.
The prior days ending NAV
per share
the dividend/distribution
for each class
(unrounded) for each class
is agreed to the
are accurately computed on
a daily basis. prior
day's Worksheet.
2. The daily net
capital stock activity for
each class for the current
day is agreed to the
Supersheet as described in
Control Procedures A.1, 2.
and 3., above.
CONTROL POLICIES
CONTROL OBJECTIVES AND PROCEDURES
3. Percentage Assets
by Class and Percentage
Dividend Assets by Class
are calculated for each
class based upon
information from the prior
day Worksheet, the
Supersheet and the telefax
from the transfer agent.
4. Allocate
investment income between
classes based on the
appropriate asset
allocation percentage for
each class.
5. Agree composite
income accounts, management
fees, other expenses,
realized gains and losses,
and unrealized
appreciation/depreciation
to the primary accounting
system of the Fund.
6. Allocate expenses
between classes as follows:
a. Expenses
directly attributable to
each class (12b-1
distribution expenses) are
calculated and
recorded to that class.
b. Expenses
attributable to both
classes are allocated in
accordance with the
appropriate asset
allocation percentage for
each class.
7. Allocate realized
and unrealized gains and
losses between the
classes in accordance with
the appropriate asset
allocation percentage of
each class.
8. Record
dividends/distributions to
shareholders of each class
in the primary accounting
system.
9. Aggregate the net
assets for each class and
agree to the total net
assets per the primary
accounting system.
10. For each class,
reconcile the current day's
NAV and, if applicable, the
dividend/distribution to
the previous day's NAV and
dividend/distribution for
each class.
CONTROL POLICIES
CONTROL OBJECTIVES AND PROCEDURES
11. The above procedures
are reviewed by the Fund
supervisor or manager.
SECTION II
Tests of Operating Effectiveness
Prudential Dual Pricing Worksheet
July 1, 1993 to June 30, 1994
We reviewed the methodology and procedures for calculating the
daily net asset value and, if applicable, the
dividends/distributions of the two classes of shares and the
allocation of income and expenses between the two classes of
shares.
The following are the detailed procedures which we performed with
respect to the Worksheet. These procedures were performed for
selected days encompassing all Funds subject to dual pricing during
the year ended June 30, 1994, which we believe is a representative
sample, to test compliance with the control policies and procedures
as described in Section I.
Prudential Mutual Fund Management, Inc. is the manager of the Funds
and has represented to us that adequate facilities are in place to
ensure implementation of the methodology and procedures for
calculating the net asset value and dividends/distributions of the
two classes of shares and the allocation of income and expenses
between the two classes of shares. Based on our review of the
description of the policies and procedures of the Worksheet, as
described in Section I, and performance of tests of operating
effectiveness as described in Section II, we concur with such
representation.
Agreed "Prior Day NAV Per Share" to the previous day's
Worksheet.
Agreed "Shares Outstanding Beginning of the Day" to the
previous day's Worksheet and to the transfer agency records
for each class.
Recalculated "Activity/Estimate" by adding the estimated
interim share activity reported via fax from the transfer
agent and the current day's "Capital Stock Activity" reported
on the Supersheet for each class.
Recalculated "Current Shares Outstanding" by adding
"Shares Outstanding Beginning of the Day" and
"Activity/Estimate" for each class.
Recalculated for each class "Adjusted Total Assets" by
multiplying "Prior Day NAV Per Share" by "Current Shares
Outstanding".
Recalculated "Percentage Assets-Class A/Front End" by
dividing "Adjusted Total Assets-Class A/Front End" by
"Adjusted Total Assets Composite".
Recalculated "Percentage Assets-Class B(D)/Back End" by
dividing "Adjusted Total Assets-Class B(D)/Back End" by
"Adjusted Total Assets Composite".
Agreed "Dividend Shares" to the transfer agency records
for each class.
Recalculated "Current Dividend Shares" by adding
"Dividend Shares Beginning of Day" and "Activity/Estimate" for
each class.
Recalculated for each class "Adjusted Dividend Assets" by
multiplying "Prior Day NAV Per Share" by "Current Dividend
Shares".
Recalculated "Percentage Dividend Assets-Class A/Front
End" by dividing "Adjusted Dividend Assets-Class A/Front End"
by "Adjusted Dividend Assets Composite".
Recalculated "Percentage Dividend Assets-Class B(D)/Back
End" by dividing "Adjusted Dividend Assets-Class B(D)/Back
End" by "Adjusted Dividend Assets Composite".
Agreed composite total of each component of income to the
primary accounting system.
Recalculated the allocation for each class of each
component of income for daily dividend funds by multiplying
the composite total by "Percentage Dividend Assets-Class
A/Front End" and "Percentage Dividend Assets-Class B(D)/Back
End," and for non-daily dividend funds by multiplying the
composite total by "Percentage Assets-Class A/Front End" and
"Percentage Assets-Class B(D)/Back End".
Recalculated "Daily Income," composite and for each
class, by totaling each component of income.
Agreed composite total "Management Fee" and "Other Fixed
Expenses" to the primary accounting system.
Recalculated the allocation for each class of "Management
Fee" and "Other Fixed Expenses" for daily dividend funds by
multiplying the composite total by "Percentage Dividend Assets-
Class A/Front End" and "Percentage Dividend Assets-Class
B(D)/Back End," and non-daily dividend funds by multiplying
the composite total by "Percentage Assets-Class A/Front End"
and "Percentage Assets-Class B(D)/Back End".
Agreed the "12b-1 Fee-Class A/Front End" and "12b-1 Fee-
Class B(D)/Back End" to the respective "PC Expense Worksheet".
Recalculated "Daily Expense," composite and for each
class, by totaling "Management Fee," "12b-1 Fee" and "Other
Fixed Expenses".
Recalculated "Daily Net Income" for each class by
subtracting "Daily Expense" from "Daily Income".
Recalculated "Dividend Rate" for each class for daily
dividend funds by dividing "Daily Net Income" by "Dividend
Shares Beginning of Day-Class A/Front End" and "Dividend
Shares Beginning of Day-Class B(D)/Back End".
Agreed "Daily Income" and "Income Distribution" for each
class to the primary accounting system.
Agreed the "Capital Gain Distribution" to the amount
recorded in the primary accounting system.
Agreed composite total "Realized Gain/Loss" and
"Unrealized Appreciation/Depreciation" to the primary
accounting system.
Recalculated the allocation for each class of "Realized
Gain/Loss" and "Unrealized Appreciation/Depreciation" by
multiplying the composite amount by the "Percentage Assets-
Class A/Front End" and "Percentage Assets-Class B(D)/Back
End".
Agreed "Prior Days Net Assets" to the previous day's
Worksheet.
Recalculated "Net Assets", composite and for each class,
by totaling "Daily Net Income", "Income Distributed", "Capital
Stock Activity", "Capital Gain Distribution", "Realized
Gain/Loss", "Unrealized Appreciation/Depreciation", and "Prior
Days Net Assets".
Recalculated "NAV Per Share" dividing the "Net Assets-
Class A/Front End" and "Net Assets - Class B(D)/Back End" by
"Current Shares Outstanding - Class A/Front End" and "Current
Shares Outstanding - Class B(D)/Back End", respectively.
Recalculated "Offering Price" for Class A shares by
applying the "Load" percentage as stated in the fund's
prospectus.