June 25, 1997
COMSTOCK PARTNERS FUNDS, INC.
Supplement to Statement of Additional Information
Dated September 3, 1996
As revised December 16, 1996
The following information replaces the relevant information
contained in the following indicated sections of the Statement of Additional
Information ("SAI") of Comstock Partners Funds, Inc.:
Under the caption "Additional Information Concerning Portfolio
Activities-Options, Futures and Currency Transactions" on page 3 of the SAI,
the phrase "cash or cash equivalents (or other instruments permitted under
applicable regulations)" appearing in the second to last sentence of the
first paragraph thereunder is replaced by the phrase "liquid assets".
Under the caption "Additional Information Concerning Portfolio
Activities-Options, Futures and Currency Transactions-Writing Covered Options
on Securities" on page 4 of the SAI, the phrase "in a separate account cash
or short-term United States Government securities" appearing in the second
sentence of the second paragraph thereunder is replaced by the phrase "in a
segregated account liquid assets".
Under the caption "Additional Information Concerning Portfolio
Activities-Options, Futures and Currency Transactions-Purchase and Sale of
Options and Futures Contracts on Stock Indices" on page 5 of the SAI, the
phrase "cash or cash equivalents (or other instruments permitted under
applicable regulations) or a combination thereof" appearing in the second to
last sentence of the second paragraph thereunder is replaced by the phrase
"liquid assets".
Under the caption "Additional Information Concerning Portfolio
Activities-Options, Futures and Currency Transactions-Foreign Currency
Transactions" on pages 6-7 of the SAI, the phrase "cash, cash equivalents or
readily marketable securities" appearing in the seventh sentence of the first
paragraph thereunder is replaced with "liquid assets".
Under the caption "Additional Information Concerning Portfolio
Activities-Short-Selling" on page 8 of the SAI, the phrase "cash, U.S.
Government Securities, or other instruments permitted under applicable
regulations" appearing in the second sentence thereunder is replaced with
"liquid assets".
Under the caption "Additional Information Concerning Portfolio
Activities-Leverage Through Borrowing (Capital Value Fund only) on page 12 of
the SAI, the phrase "cash or U.S. Government securities or other high quality
liquid debt securities" appearing in the second to last sentence of the
paragraph is replaced with "liquid assets".
<PAGE>
June 25, 1997
COMSTOCK PARTNERS FUNDS, INC.
Supplement to Prospectus dated September 3, 1996
The following information supplements or replaces the relevant
information contained in the following indicated sections of the Prospectus
of Comstock Partners Funds, Inc.
Under the caption "Derivatives Transactions-Options, Futures and
Currencies" on page 25 of the Prospectus, the phrase "cash or cash
equivalents" appearing in the third sentence thereunder is replaced by the
phrase "liquid assets".
Under the caption "Forward Commitments" on page 29 of the
Prospectus, the second to last sentence thereunder is replaced by the
following: "A segregated account of a Fund consisting of liquid assets at
least equal at all times to the amount of the when-issued or forward
commitments will be established and maintained at such Fund's custodian
bank."
The following information supersedes any contrary information
contained in the Fund's Prospectus.
The Telephone Redemption Privilege is granted automatically
unless you specifically refuse it by checking the applicable "No" box on
the Account Application. The Telephone Redemption Privilege may be established
for an existing account by a separate signed Shareholder Services Form or by
oral request from any of the authorized signatories on the account by calling
1-800-645-6561.
