AMERICAN CAPITAL PACE FUND INC
497J, 1997-10-31
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                                                                         497(j)

                               October 31, 1997



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

   Re:  Van Kampen American Capital Pace Fund --
        Rule 497(j) Filing (File Nos. 2-31417 and 811-01792)

Ladies and Gentlemen:

        Van Kampen American Capital Pace Fund (the "Registrant"), filed via 
EDGAR on October 27, 1997, a copy of Post-Effective Amendment No. 47 to the     
Registration Statement on Form N-1A (the "Registration Statement") complete
with exhibits filed therewith pursuant to Rule 485(b) of the General Rules and
Regulations (the "1933 Act Rules") of the Securities and Exchange Commission
promulgated under the Securities Act of 1933, as amended (the "Securities
Act"), and under the Investment Company Act of 1940, as amended.

        In accordance with the provisions of Rule 497(j) of the 1933 Act Rules  
this letter serves to certify that the prospectus and statement of additional 
information contained in the Registration Statement do not differ from that 
which would have been filed pursuant to Rule 497(c) of the Securities Act.

        Should the staff have any questions regarding the foregoing, please
contact me at (630) 634-6774.


                                                Very truly yours,


                                                /s/ Nicholas Dalmaso
                                                -------------------------
                                                Nicholas Dalmaso
                                                Assistant Secretary


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