COMSTOCK PARTNERS FUNDS, INC.
Supplement dated December 17, 1999 to Prospectus dated August 28, 1999
On December 14, 1999, the Board of Directors of Comstock Partners Funds,
Inc. (the "Company") unanimously approved proposals to engage affiliates of
Gabelli Asset Management Inc. as investment adviser and distributor for each
of the Funds, subject to shareholder approval at a special meeting of
shareholders to be held in 2000.
The Board's actions follow agreements recently entered into by Comstock
Partners, Inc., the Funds' investment adviser, and Charles Minter, the owner
of Comstock Partners, with Gabelli Funds, LLC, under which Comstock Partners
will sell substantially all of its assets to Gabelli Funds, and Charles
Minter and Martin Weiner will be employed by Gabelli Funds and will continue
to serve as co-portfolio managers of the Funds. The proposed new investment
advisory agreements would provide for a single fee covering investment
advisory and administrative services, which would be 0.85% of average daily
net assets for the Strategy Fund and 1.00% of average daily net assets for
the Capital Value Fund. Gabelli Funds would waive a portion of its
management fees for the first two years to maintain expense ratios for the
Funds at 1999 levels (other than extraordinary expenses) with respect to the
amount of assets held by each Fund at the time each new advisory agreement
goes into effect.
