Exhibit to Accompany
Item 77J
Form N-SAR
Universal Capital Growth Fund
(the "Fund")
According to the provisions of Statement of
Position 93 - 2 (SOP 93 - 2) "Determination,
Disclosure and Financial Statement
Presentation of Income, Capital Gain and
Return of Capital Distributions by Investment
Companies," the Fund is required to report
the accumulated net investment income (loss)
and accumulated net capital gain (loss)
accounts to approximate amounts available for
future distributions on a tax basis (or to
offset future realized capital gains). As a
result, the Fund has reclassified accumulated
net investment losses to reduce paid in capital
by $248,041 for the year ended
September 30, 2000.
This reclassification has no impact on the
net asset value of the Fund and is designed
to present the Fund's capital accounts on a
tax basis.
