NICHOLAS APPLEGATE FUND INC
NSAR-B, 1998-03-03
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SIGNATURE   GRACE TORRES                                 
TITLE       TREASURER           
 


<TABLE> <S> <C>











<ARTICLE> 6
<CIK> 0000810212
<NAME> NICHOLAS APPLEGATE FUND, INC.
<SERIES>
   <NUMBER> 001
   <NAME> NICHOLAS APPLEGATE FUND, INC. (CLASS A)
       
<S>                             <C>
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<TABLE> <S> <C>











<ARTICLE> 6
<CIK> 0000810212
<NAME> NICHOLAS APPLEGATE FUND, INC.
<SERIES>
   <NUMBER> 002
   <NAME> NICHOLAS APPLEGATE FUND, INC. (CLASS B)
       
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<TABLE> <S> <C>











<ARTICLE> 6
<CIK> 0000810212
<NAME> NICHOLAS APPLEGATE FUND, INC.
<SERIES>
   <NUMBER> 003
   <NAME> NICHOLAS APPLEGATE FUND, INC. (CLASS C)
       
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<TABLE> <S> <C>











<ARTICLE> 6
<CIK> 0000810212
<NAME> NICHOLAS APPLEGATE FUND, INC.
<SERIES>
   <NUMBER> 004
   <NAME> NICHOLAS APPLEGATE FUND, INC. (CLASS Z)
       
<S>                             <C>
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</TABLE>

January 21, 1998

Ernst & Young LLP
515 South Flower
Los Angeles, CA, 90071


In   connection  with  your  audit   of   the
statement    of   assets   and   liabilities,
including  the  schedule  of  investments  of
Nicholas  Applegate Growth Equity  Fund  (the
"Fund")  as  of  December 31, 1997,  and  the
related statements of operations, changes  in
net  assets, and financial highlights for the
year  then ended, we recognize that obtaining
representations   from  us   concerning   the
information  contained in this  letter  is  a
significant procedure in enabling you to form
an  opinion  whether the financial statements
and  financial highlights present fairly,  in
all    material   respects,   the   financial
position,  results of operations, changes  in
net  assets and financial highlights  of  the
Fund  in  conformity with generally  accepted
accounting  principles, and  accordingly,  we
make  the following representations  ,  which
are  true  to  the best of our knowledge  and
belief.

General

We  recognize that, as members of  management
of  the Fund, we are responsible for the fair
presentation of its financial statements.  We
believe the statements of financial position,
results of operations, changes in net  assets
and financial highlights are fairly presented
in   conformity   with   generally   accepted
accounting  principles  applied  on  a  basis
consistent with that of the preceding period.

We    have    made    available    to    your
representatives  all  financial  records  and
related data.

We  have  no  plans  or intentions  that  may
materially  affect  the  carrying  value   or
classification of assets and liabilities.

Internal Control

There are no material transactions that  have
not  been properly recorded in the accounting
records underlying the financial statements.

There  are no material weaknesses in internal
control,  including any for which we  believe
the  cost  of corrective actions exceeds  the
benefits.  There  have  been  no  significant
changes  in  internal control since  December
31, 1997,







Minutes and Contracts

We  have made available to you all minutes of
the  meetings of stockholders, directors, and
committees  of  directors,  or  summaries  of
actions  of recent meetings for which minutes
have not yet been prepared.

We  have  made available information relating
to  all  statutes, laws, or regulations  that
have   a   direct  effect  on  our  financial
statements.

We have made available all reports from other
accountants who have been engaged to  make  a
review  of  interim financial information  of
significant   components  of  the   reporting
entity,   its  subsidiaries,  or  its   other
investees  and  all information  relating  to
contracts  with  and  results  of   work   by
specialists.

We   have   complied  with  all  aspects   of
contractual  agreements  that  would  have  a
material  effect on the financial  statements
in the event of noncompliance.

Risks and Uncertainties

There  are no risks and uncertainties related
to  certain significant estimates and current
vulnerabilities due to certain concentrations
that  have  not been disclosed in  accordance
with   AICPA  Statement  of  Position   94-6,
Disclosure of Certain Significant  Risks  and
Uncertainties.

Ownership and Pledging of Assets

The  Fund has satisfactory title to all owned
assets, including all assets appearing in the
statement  of  assets  and  liabilities,  and
there  are no liens or encumberances on  such
assets, nor has any asset been pledged except
as disclosed in the financial statements.

Investments

Portfolio securities are stated at fair value
as   determined   in  accordance   with   the
valuation  methods set forth in  the  current
prospectus.  All Fund investments during  the
period  were  made  in  accordance  with  the
investment  policies stated  in  the  current
prospectus.

The  Fund complied with the provisions of the
Investment Fund Act of 1940, as amended  (the
"Act"),   and   the  rules  and   regulations
thereunder,  and with the provisions  of  its
prospectus  and  the  requirements   of   the
various  Blue Sky laws under which  the  Fund
operates.  The daily net asset value has been
properly  computed throughout  the  year  for
open-end  funds in accordance with Rule  2a-4
of  the  Act  (or Rule 2a-7 for money  market
funds)  and  was  correctly  applied  in  the
computation of daily capital stock sales  and
redemption transactions.

The  Fund did not make any commitments during
the  year as underwriter, and did not  engage
in  any transactions made on margin, in joint
trading or in a joint investment account,  or
in selling short.

The  Fund  has complied with the requirements
of  Subchapter M of the Internal Revenue Code
of  1986, as amended through the date of this
letter, and intends to continue to so comply.

The  Fund, except to the extent indicated  in
its  financial statements, does not  own  any
securities   of  persons  who  are   directly
affiliated  as defined in Section 2(a)(3)  of
the Act.

There  were  no  investments  in  issuers   5
percent  or  more  of whose  securities  were
owned by officers and directors of the Fund.

All  financial  instruments, including  those
with  off-balance-sheet risk (such as  swaps,
forwards  and  futures),  as  required  under
generally accepted accounting principles have
been  properly recorded or disclosed  in  the
financial statements.

The Fund has complied with the provisions  of
its code of ethics.

Related Party Transactions

Transactions with related parties, as defined
in    Statement   of   Financial   Accounting
Standards No. 57, and other transactions with
affiliates,   including  fees,   commissions,
purchases   and  sales  have  been   properly
recorded   or  disclosed  in  the   financial
statements.

Arrangements with Financial Institutions

Arrangements   with  financial   institutions
involving  compensating  balances  or   other
arrangements involving restrictions  on  cash
balances   and  line-of-credit   or   similar
arrangements have been properly  recorded  or
disclosed in the financial statements.

Contingent Liabilities

There    are   no   unasserted   claims    or
assessments, including those our lawyers have
advised us of, that are probable of assertion
and  must  be  disclosed in  accordance  with
Statement  of Financial Accounting  Standards
No.  5,  "Accounting for Contingencies (other
than   those   disclosed  in  the   financial
statements).

There  have  been no violations  or  possible
violations  of  laws  or regulations  in  any
jurisdiction   whose   effects   should    be
considered  for disclosure in  the  financial
statements or as a basis for recording a loss
contingency  (other than those  disclosed  in
the financial statements).

There   have  been  no  communications   from
regulatory  agencies, such as the  Securities
and   Exchange  Commission  or  the  Internal
Revenue Service, concerning investigations or
allegations  of noncompliance  with  laws  or
regulations    in   any   jurisdiction,    or
deficiencies in financial reporting practices
or  other  matters that could have a material
effect on the financial statements.

There  are  no other material liabilities  or
gain  or loss contingencies that are required
to  be  accrued or disclosed by Statement  of
Financial Accounting Standards No.  5  (other
than  those  accrued  or  disclosed  in   the
financial  statements)  nor  are  there   any
accruals  for loss contingencies included  in
the  statement of assets and liabilities that
are not in conformity with the provisions  of
Statement  of Financial Accounting  Standards
No. 5.

Capital Stock

Capital    stock   repurchase   options    or
agreements,  or  capital stock  reserved  for
options,   warrants,  conversions  or   other
requirements have been properly  recorded  or
disclosed in the financial statements.

Fraud and Conflicts of Interest

There   have  been  no  instances  of   fraud
involving  management or employees  who  have
significant roles in internal control.  There
have  been  no  instances of fraud  involving
other  employees that could have  a  material
effect on the financial statements.

There  are no instances where any officer  or
employee  of  the Fund has an interest  in  a
Fund  with which the Fund does business  that
would be considered a "conflict of interest."
Such  an  interest would be contrary to  Fund
policy.

Subsequent Events

No events or transactions have occurred since
the  statement of assets and liabilities date
or  are  pending that would have  a  material
effect  on the financial statements  at  that
date  or  for the period then ended, or  that
are  of such significance in relation to  the
Fund's  affairs to require mention in a  note
to  the financial statements in order to make
them  not  misleading regarding the financial
position,  results of operations, changes  in
nets assets, and financial highlights of  the
Fund.   We  are  not  aware  of  any  matters
arising  during the year ended  December  31,
1997   that   would  materially  affect   the
comparative  statement  of  changes  in   net
assets  for the year ended December 31,  1996
or  the  financial highlights  for  the  four
years in the period ended December 31, 1996.







We  understand that your audit was  conducted
in   accordance   with   generally   accepted
auditing  standards as defined and  described
by the American Institute of Certified Public
Accountants  and  was,  therefore,   designed
primarily  for  the purpose of expressing  an
opinion  on the financial statements  of  the
Fund taken as a whole, and that your tests of
the  accounting  records and  other  auditing
procedures  were limited to  those  that  you
considered necessary for that purpose.

                                   Very truly
                                   yours,


                                   Nicholas
                                   Applegate
                                   Growth
                                   Equity
                                   Fund
                                   
                                   President/
                                   Chief
                                   Executive
                                   Officer
                                   
                                   Treasurer/
                                   Chief
                                   Financial
                                   Officer
 
                                   


                                      - 2 -











Board of Directors or Trustees of:


Prudential Adjustable Rate       Pruden
Securities Fund*                 tial
Prudential Allocation Fund (2    High
Portfolios)                      Yield
The BlackRock Government Income  Fund
Trust                            Pruden
Global Utility Fund              tial
Nicholas-Applegate Fund          Income
Prudential California Municipal  Vertib
Fund (2 Portfolios)              le
Prudential Distressed            Fund*
Securities Fund                  Pruden
Prudential Diversified Bond      tial
Fund                             Interm
Prudential Equity Fund           ediate
Prudential Equity Income Fund    Global
Prudential Global Genesis Fund   Income
Prudential Global Limited        Fund
Maturity Fund                    Pruden
Prudential Global Natural        tial
Resources Fund                   Jennis
The Global Government Plus Fund  on
The                              Fund
Global                           Pruden
Total                            tial
Return                           MoneyM
Fund                             art
Pruden                           Assets
tial                             Pruden
Govern                           tial
ment                             Mortga
Income                           ge
Fund                             Income
Pruden                           Fund
 tial                            Pruden
 Gover                           tial
 nment                           Multi-
 Secur                           Sector
 ities                           Fund
 Trust                           Pruden
 -                               tial
 Money                           Munici
 Marke                           pal
 t                               Bond
 Serie                           Fund
 s                               (3
                                 Portfo
                                 lios)
                                 Pruden
                                 tial
                                 Munici
                                 pal
                                 Series
                                 Fund
                                 (10
                                 curren
                                 t
                                 
                                 Portfo
                                 lios
                                 and 3
                                 merged
                                 Portfo
                                 lios*)
                                 Pruden
                                 tial
                                 Nation
                                 al
                                 Munici
                                 pals
                                 Fund
                                 Pruden
                                 tial
                                 Pacifi
                                 c
                                 Growth
                                 Fund
                                 Pruden
                                 tial
                                 Small
                                 Compan
                                 ies
                                 Fund
                                 Pruden
                                 tial
                                 Struct
                                 ured
                                 Maturi
                                 ty
                                 Fund
                                 Pruden
                                 tial
                                 U.S.
                                 Govern
                                 ment
                                 Fund*
                                 Pruden
                                 tial
                                 Utilit
                                 y Fund
                                 Pruden
                                 tial
                                 World
                                 Fund
                                 
*  As of June 30, 1996, the Fund/Portfolio was no
 longer in operation.  The Fund/Portfolio merged into
 another Fund within the Prudential Mutual Fund
 Family.
 
We have examined the accompanying description of the
Prudential Multiple Class 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, 1996.  The
control objectives were specified by Prudential Mutual
Fund Management, Inc.  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, 1996.  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, 1995 to June 30, 1996.  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, 1995 to June 30, 1996.
However, the scope of our engagement did not include
tests to determine whether control objectives not
listed  in Section I were achieved; accordingly we
express no opinion on the achievement of control
objectives not included in Section I.

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, 1996, and information about
tests of the operating effectiveness of specified
policies and procedures covers the period from July 1,
1995 to June 30, 1996.  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.





August 23, 1996





                                    SECTION I

                   Policies and Procedures Placed in Operation
                   Prudential Multiple Class Pricing Worksheet
                                        
                                        
The Prudential Mutual Funds (the "Funds") have adopted
a multiple class pricing system.  The multiple class
pricing system consists of four classes of shares
(Class A, Class B, Class C and Class Z).  Class A
shares are subject to an initial sales charge, Class B
and Class C shares are subject to a contingent deferred
sales charge and Class Z shares have no sales charge
(Class Z shares which were first offered on March 1,
1996, are offered exclusively for sale to the PSI
Pension Plan).  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 among the
classes of shares, State Street Bank and Trust Company
(the Funds' custodian and recordkeeper) utilizes the
Prudential Multiple Class 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 among the 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 specific control objectives and policies and
procedures relating to the Worksheet are described on
pages 4 and 5.  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 Multiple Class 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
       CONTROL OBJECTIVES                     POLICIES
                                                 AND
                                              PROCEDUR
                                                 ES
                                                  
A. Capital share activity as         1. Daily
reported by the Fund's transfer      , the
agent is recorded for each class     trans
in an accurate and timely manner     fer
by the Fund.                         agent
                                     forwa
                                     rds
                                     repor
                                     ts of
                                     capit
                                     al
                                     share
                                     activ
                                     ity
                                     for
                                     each
                                     class
                                     which
                                     inclu
                                     des a
                                     summa
                                     ry of
                                     subsc
                                     ripti
                                     ons,
                                     redem
                                     ption
                                     s,
                                     excha
                                     nges
                                     and
                                     other
                                     infor
                                     matio
                                     n
                                     (the
                                     "Supe
                                     rshee
                                     t").
                                     The
                                     openi
                                     ng
                                     day's
                                     balan
                                     ce
                                     for
                                     share
                                     s
                                     outst
                                     andin
                                     g and
                                     curre
                                     nt
                                     day
                                     activ
                                     ity
                                     is
                                     recor
                                     ded
                                     on
                                     the
                                     Works
                                     heet.
                                     
                                  2. Estim
                                     ated
                                     inter
                                     im
                                     share
                                     activ
                                     ity
                                     for
                                     the
                                     curre
                                     nt
                                     day
                                     not
                                     recor
                                     ded
                                     in
                                     the
                                     Super
                                     sheet
                                     is
                                     recei
                                     ved
                                     via
                                     telef
                                     ax
                                     from
                                     the
                                     trans
                                     fer
                                     agent
                                     and
                                     is
                                     recor
                                     ded
                                     for
                                     each
                                     class
                                     on
                                     the
                                     Works
                                     heet.
                                     
                                  3. A
                                     repor
                                     t of
                                     outst
                                     andin
                                     g
                                     share
                                     s
                                     eligi
                                     ble
                                     for
                                     divid
                                     ends
                                     is
                                     recei
                                     ved
                                     from
                                     the
                                     trans
                                     fer
                                     agent
                                     and
                                     is
                                     recor
                                     ded
                                     for
                                     each
                                     class
                                     on
                                     the
                                     Works
                                     heet.
                                     
B. Net Asset Value ("NAV") and, if   1. The
applicable, the                      prio
dividend/distribution for each       r
class are accurately computed on     days
a daily basis.                       endi
                                     ng
                                     NAV
                                     per
                                     shar
                                     e
                                     (b)
                                     for
                                     each
                                     clas
                                     s is
                                     agre
                                     ed
                                     to
                                     the
                                     prio
                                     r
                                     day'
                                     s
                                     Work
                                     shee
                                     t.
                                     
                                  2. The
                                     dail
                                     y
                                     net
                                     capi
                                     tal
                                     stoc
                                     k
                                     acti
                                     vity
                                     for
                                     each
                                     clas
                                     s
                                     for
                                     the
                                     curr
                                     ent
                                     day
                                     is
                                     agre
                                     ed
                                     to
                                     the
                                     Supe
                                     rshe
                                     et
                                     as
                                     desc
                                     ribe
                                     d in
                                     Cont
                                     rol
                                     Proc
                                     edur
                                     es
                                     A.1.
                                     , 2.
                                     and
                                     3.,
                                     abov
                                     e.
                                     
                                     3. Perc
                                     enta
                                     ge
                                     Asse
                                     ts
                                     by
                                     Clas
                                     s
                                     and
                                     Perc
                                     enta
                                     ge
                                     Divi
                                     dend
                                     Asse
                                     ts
                                     by
                                     Clas
                                     s
                                     are
                                     calc
                                     ulat
                                     ed
                                     for
                                     each
                                     clas
                                     s
                                     base
                                     d
                                     upon
                                     info
                                     rmat
                                     ion
                                     from
                                     the
                                     prio
                                     r
                                     day
                                     Work
                                     shee
                                     t,
                                     the
                                     Supe
                                     rshe
                                     et
                                     and
                                     the
                                     tele
                                     fax
                                     from
                                     the
                                     tran
                                     sfer
                                     agen
                                     t.
                                     

                                               CONTROL
       CONTROL OBJECTIVES                     POLICIES
                                                 AND
                                              PROCEDUR
                                                 ES
                                                  
                                     4. Allo
                                     cate
                                     inve
                                     stme
                                     nt
                                     inco
                                     me
                                     amon
                                     g
                                     clas
                                     ses
                                     base
                                     d on
                                     the
                                     appr
                                     opri
                                     ate
                                     asse
                                     t
                                     allo
                                     cati
                                     on
                                     perc
                                     enta
                                     ge
                                     for
                                     each
                                     clas
                                     s.
                                     
                                     5. Agre
                                     e
                                     comp
                                     osit
                                     e
                                     inco
                                     me
                                     acco
                                     unts
                                     ,
                                     mana
                                     geme
                                     nt
                                     fees
                                     ,
                                     othe
                                     r
                                     expe
                                     nses
                                     ,
                                     real
                                     ized
                                     gain
                                     s
                                     and
                                     loss
                                     es,
                                     and
                                     unre
                                     aliz
                                     ed
                                     appr
                                     ecia
                                     tion
                                     /dep
                                     reci
                                     atio
                                     n to
                                     the
                                     prim
                                     ary
                                     acco
                                     unti
                                     ng
                                     syst
                                     em
                                     of
                                     the
                                     Fund
                                     .
                                     
                                  6. Allo
                                     cate
                                     expe
                                     nses
                                     amon
                                     g
                                     clas
                                     ses
                                     as
                                     foll
                                     ows:
                                     
                                        a. E
                                         x
                                         p
                                         e
                                         n
                                         s
                                         e
                                         s
                                         d
                                         i
                                         r
                                         e
                                         c
                                         t
                                         l
                                         y
                                         a
                                         t
                                         t
                                         r
                                         i
                                         b
                                         u
                                         t
                                         a
                                         b
                                         l
                                         e
                                         t
                                         o
                                         e
                                         a
                                         c
                                         h
                                         c
                                         l
                                         a
                                         s
                                         s
                                         (
                                         1
                                         2
                                         b-
                                         1
                                         d
                                         i
                                         s
                                         t
                                         r
                                         i
                                         b
                                         u
                                         t
                                         i
                                         o
                                         n
                                         e
                                         x
                                         p
                                         e
                                         n
                                         s
                                         e
                                         s
                                         )
                                         a
                                         r
                                         e
                                         c
                                         a
                                         l
                                         c
                                         u
                                         l
                                         a
                                         t
                                         e
                                         d
                                         a
                                         n
                                         d
                                         r
                                         e
                                         c
                                         o
                                         r
                                         d
                                         e
                                         d
                                         t
                                         o
                                         t
                                         h
                                         a
                                         t
                                         c
                                         l
                                         a
                                         s
                                         s
                                         .
                                         
                                     b. E
                                         x
                                         p
                                         e
                                         n
                                         s
                                         e
                                         s
                                         a
                                         t
                                         t
                                         r
                                         i
                                         b
                                         u
                                         t
                                         a
                                         b
                                         l
                                         e
                                         t
                                         o
                                         b
                                         o
                                         t
                                         h
                                         c
                                         l
                                         a
                                         s
                                         s
                                         e
                                         s
                                         a
                                         r
                                         e
                                         a
                                         l
                                         l
                                         o
                                         c
                                         a
                                         t
                                         e
                                         d
                                         i
                                         n
                                         a
                                         c
                                         c
                                         o
                                         r
                                         d
                                         a
                                         n
                                         c
                                         e
                                         w
                                         i
                                         t
                                         h
                                         t
                                         h
                                         e
                                         a
                                         p
                                         p
                                         r
                                         o
                                         p
                                         r
                                         i
                                         a
                                         t
                                         e
                                         a
                                         s
                                         s
                                         e
                                         t
                                         a
                                         l
                                         l
                                         o
                                         c
                                         a
                                         t
                                         i
                                         o
                                         n
                                         p
                                         e
                                         r
                                         c
                                         e
                                         n
                                         t
                                         a
                                         g
                                         e
                                         f
                                         o
                                         r
                                         e
                                         a
                                         c
                                         h
                                         c
                                         l
                                         a
                                         s
                                         s
                                         .
                                         
                                     7. Allo
                                     cate
                                     real
                                     ized
                                     and
                                     unre
                                     aliz
                                     ed
                                     gain
                                     s
                                     and
                                     loss
                                     es
                                     amon
                                     g
                                     the
                                     clas
                                     ses
                                     in
                                     acco
                                     rdan
                                     ce
                                     with
                                     the
                                     appr
                                     opri
                                     ate
                                     asse
                                     t
                                     allo
                                     cati
                                     on
                                     perc
                                     enta
                                     ge
                                     of
                                     each
                                     clas
                                     s.
                                     
                                  8. Reco
                                     rd
                                     divi
                                     dend
                                     s/di
                                     stri
                                     buti
                                     ons
                                     to
                                     shar
                                     ehol
                                     ders
                                     of
                                     each
                                     clas
                                     s in
                                     the
                                     prim
                                     ary
                                     acco
                                     unti
                                     ng
                                     syst
                                     em.
                                     
                                  9. Aggr
                                     egat
                                     e
                                     the
                                     net
                                     asse
                                     ts
                                     for
                                     each
                                     clas
                                     s
                                     and
                                     agre
                                     e to
                                     the
                                     tota
                                     l
                                     net
                                     asse
                                     ts
                                     per
                                     the
                                     prim
                                     ary
                                     acco
                                     unti
                                     ng
                                     syst
                                     em.
                                     
                                  10.For
                                     each
                                     clas
                                     s,
                                     reco
                                     ncil
                                     e
                                     the
                                     curr
                                     ent
                                     day'
                                     s
                                     NAV
                                     and,
                                     if
                                     appl
                                     icab
                                     le,
                                     the
                                     divi
                                     dend
                                     /dis
                                     trib
                                     utio
                                     n to
                                     the
                                     prev
                                     ious
                                     day'
                                     s
                                     NAV
                                     and
                                     divi
                                     dend
                                     /
                                     dist
                                     ribu
                                     tion
                                     for
                                     each
                                     clas
                                     s.
                                     
                                  11.The
                                     abov
                                     e
                                     proc
                                     edur
                                     es
                                     are
                                     revi
                                     ewed
                                     by
                                     the
                                     Fund
                                     supe
                                     rvis
                                     or
                                     or
                                     mana
                                     ger.
                                     

                                   SECTION II

                        Tests of Operating Effectiveness
                   Prudential Multiple Class Pricing Worksheet
                          July 1, 1995 to June 30, 1996
                                        
                                        
We reviewed the methodology and procedures for
calculating the daily net asset value and, if
applicable, the dividends/distributions of the classes
of shares and the allocation of income and expenses
among the 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 multiple class
pricing during the year ended June 30, 1996, 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 classes
of shares and the allocation of income and expenses
among the 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(C)/Back
   End" by dividing "Adjusted Total Assets-Class
   B(C)/Back End" by "Adjusted Total Assets
   Composite".
   
   Recalculated "Percentage Assets-Class Z/No Fee"
   where applicable, by dividing "Adjusted Total
   Assets-Class Z/No Fee" 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(C)/Back End" by dividing "Adjusted Dividend
   Assets-Class B(C)/Back End" by "Adjusted Dividend
   Assets Composite".
   
   Recalculated "Percentage Dividend Assets-Class Z/No
   Fee" where applicable, by dividing "Adjusted
   Dividend Assets-Class Z" 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", "Percentage
   Dividend Assets-Class B(C)/Back End" and where
   applicable, "percentage Dividend Assets-Class Z/No
   Fee", and for non-daily dividend funds by
   multiplying the composite total by "Percentage
   Assets-Class A/Front End", "Percentage Assets-Class
   B(C)/Back End" and where applicable, "Percentage
   Assets-Class Z/No Fee".
   
   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", "Percentage Dividend Assets-Class B(C)/Back
   End" and where applicable, "percentage Dividend
   Assets-Class Z/No Fee", and non-daily dividend
   funds by multiplying the composite total by
   "Percentage Assets-Class A/Front End", "Percentage
   Assets-Class B(C)/Back End" " and where applicable,
   "Percentage Assets-Class Z/No Fee"
   
   Agreed the "12b-1 Fee-Class A/Front End" and "12b-1
   Fee-Class B(C)/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", "Dividend Shares Beginning of Day-Class
   B(C)/Back End" and where applicable, "Dividend
   Shares Beginning of Day-Class Z/No Fee".
   
   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", "Percentage  Assets-Class B(C)/Back
   End" and where applicable, "Percentage Assets-Class
   Z/No Fee".
   
   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
   nDistributed", "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", "Net Assets - Class
   B(C)/Back End" and where applicable, "Net Assets-
   Class Z/No Fee" by "Current Shares Outstanding -
   Class A/Front End", "Current Shares Outstanding -
   Class B(C)/Back End" and where applicable, "Current
   Shares Outstanding-Class Z/No Fee", respectively.
   
   Recalculated "Offering Price" for Class A shares by
   applying the "Load" percentage as stated in the
   fund's prospectus.
   




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