PILGRIM GROWTH & INCOME FUND INC
N-14, EX-14, 2000-12-19
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                                                                      Exhibit 14

                          INDEPENDENT AUDITORS' CONSENT

The Board of Directors
Pilgrim Growth and Income Fund, Inc.:

We consent to the use of our report on the Pilgrim Growth and Income Fund
incorporated herein by reference, and to the reference to our firm under the
heading "Financial Highlights" in the Proxy Statement/Prospectus.


                                        /s/ KPMG LLP


Los Angeles, California
December 18, 2000
<PAGE>
                         CONSENT OF INDEPENDENT AUDITORS

We consent to the use of our report dated December 3, 1999 with respect to ING
Growth & Income Fund (one of the funds comprising ING Funds Trust), which is
incorporated by reference, in this Registration Statement on Form N-14 of
Pilgrim Growth and Income Fund, Inc.


                                        /s/ ERNST & YOUNG LLP


New York, New York
December 15, 2000


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