COMSTOCK FUNDS INC
485BPOS, EX-99.(A)(7), 2000-08-28
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                                                                    EXHIBIT A(7)
                                                                    ------------

                              ARTICLES OF AMENDMENT
                         OF GABELLI COMSTOCK FUNDS, INC.

         Gabelli   Comstock   Funds,   Inc.,   a   Maryland   corporation   (the
"Corporation"),  having its principal office at One Corporate  Center,  Rye, New
York 10580-1434, certifies as follows:

         FIRST:  The  Corporation  desires to amend its Charter as  currently in
effect.


         SECOND:  The  amendments  to the Charter of the  Corporation  set forth
herein shall become effective on the date and at the time that these articles of
Amendment  (these  "Articles")  are filed with,  and  approved  and accepted for
record by, the State  Department  of  Assessments  and  Taxation  of Maryland in
accordance with the Maryland General Corporation Law.

         THIRD: ARTICLE II of the Corporation's Charter is hereby deleted in its
entirety and in its place shall be inserted the following:

                                   ARTICLE II

                                      NAME
                                      ----

               The name of the Corporation is Comstock Funds, Inc.

         FOURTH: The Gabelli Comstock Strategy Fund series of the Corporation is
hereby  redesignated the Comstock Strategy Fund and in designation of each class
of shares of such series the words Comstock Strategy Fund are hereby substituted
for the words Gabelli Comstock Strategy Fund.

         FIFTH:   The  Gabelli   Comstock  Capital  Value  Fund  series  of  the
Corporation  is hereby  redesignated  the  Comstock  Capital  Value  Fund and in
designation  of each class of shares of such series the words  Comstock  Capital
Value Fund are hereby  substituted for the words Gabelli  Comstock Capital Value
Fund.

         SIXTH:  The amendments to the Charter of the  Corporation  set forth in
these  Articles  were approved by the Board of Directors of the  Corporation  in
accordance with the provisions of ss.2-605 of the Maryland  General  Corporation
Law by a unanimous consent dated July 31, 2000.

         SEVENTH: The foregoing amendments to the Charter of the Corporation are
limited to changes  expressly  permitted by ss.2-605 of Subtitle 6 of Title 2 of
the Maryland General Corporation Law to be made without action by stockholders.

         EIGHTH:  The Corporation is registered as an open-end company under the
Investment Company Act of 1940, as amended.

         IN WITNESS  WHEREOF,  Gabelli  Comstock  Funds,  Inc.  has caused these
Articles  of  Amendment  to be  executed  in its name and on its  behalf  by its
Executive Vice President who acknowledges  these Articles of Amendment to be the
corporate act of the Corporation  and, as to all matters or facts required to be
verified  under  oath,   acknowledges  that,  to  the  best  of  his  knowledge,
information and belief and under the penalties of perjury, all matters and facts
contained  herein  are  true in all  material  respects,  as of this  1st day of
August, 2000.

ATTEST:                                     GABELLI COMSTOCK FUNDS, INC.

James E. McKee                              By: Bruce N. Alpert
--------------                                  ---------------
/s/James E. McKee                           /s/ Bruce N. Alpert
Secretary                                   Executive Vice President



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