AMERICAN ODYSSEY FUNDS INC /MD/
NSAR-B, 2000-02-28
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<PAGE>      PAGE  1
000 B000000 12/31/1999
000 C000000 0000896629
000 D000000 N
000 E000000 NF
000 F000000 Y
000 G000000 N
000 H000000 N
000 I000000 6.1
000 J000000 A
001 A000000 NMERICAN ODYSSEY FUNDS, INC.
001 B000000 811-7450
001 C000000 7325142000
002 A000000 TWO TOWER CENTER
002 B000000 EAST BRUNSWICK
002 C000000 NJ
002 D010000 08816
002 D020000 1063
003  000000 N
004  000000 N
005  000000 N
006  000000 N
007 A000000 Y
007 B000000  6
007 C010100  1
007 C020100 AMERICAN ODYSSEY INTERNATIONAL EQUITY FUND
007 C030100 N
007 C010200  2
007 C020200 AMERICAN ODYSSEY EMERGING OPPORTUNITIES FUND
007 C030200 N
007 C010300  3
007 C020300 AMERICAN ODYSSEY CORE EQUITY FUND
007 C030300 N
007 C010400  4
007 C020400 AMERICAN ODYSSEY LONG-TERM BOND FUND
007 C030400 N
007 C010500  5
007 C020500 AMERICAN ODYSSEY INTERMEDIATE-TERM BOND FUND
007 C030500 N
007 C010600  6
007 C020600 AMERICAN ODYSSEY GLOBAL HIGH-YIELD BOND FUND
007 C030600 N
007 C010700  7
007 C010800  8
007 C010900  9
007 C011000 10
010 A00AA01 AMERICAN ODYSSEY FUNDS MANAGEMENT, INC
010 B00AA01 801-43443
010 C01AA01 EAST BRUNSWICK
010 C02AA01 NJ
010 C03AA01 08816
010 C04AA01 1063
<PAGE>      PAGE  2
011 A00AA01 CFBDS, INC.
011 B00AA01 8-32417
011 C01AA01 BOSTON
011 C02AA01 MA
011 C03AA01 02109
012 A00AA01 AMERICAN ODYSSEY FUNDS MANAGEMENT, INC.
012 B00AA01 85-00000
012 C01AA01 EAST BRUNSWICK
012 C02AA01 NJ
012 C03AA01 08816
012 C04AA01 1063
013 A00AA01 KPMG PEAT MARWICK, L.L.P.
013 B01AA01 BOSTON
013 B02AA01 MA
013 B03AA01 02110
014 A00AA01 TOWER SQUARE SECURITIES
014 B00AA01 8-13752
014 A00AA02 SALOMON SMITH BARNEY, INC.
014 B00AA02 8-8177
014 A00AA03 PFS DISTRIBUTORS INC
014 B00AA03 8-19253
014 A00AA04 THE ROBINSON-HUMPHREY COMPANY, LLC
014 B00AA04 8-27190
014 A00AA05 PFS INVESTMENTS, INC.
014 B00AA05 8-10111
014 A00AA06 DELETE
014 A00AA07 TRIBECA INVESTMENTS, LLC
014 B00AA07 8-40631
014 A00AA08 LEGG MASON (LONG-TERM BOND ONLY)
014 B00AA08 8-xxxx
014 A00AA09 SMITH BARNEY PUERTO RICO
014 B00AA09 8-49165
014 A00AA10 SMITH ANNUITY SERVICES
014 B00AA10 8-14495
014 A00AA11 SG COWEN SECURITIES CORP.(EMERG OPPORT. ONLY)
014 B00AA11 8-1682
014 A00AA12 SALOMON BROTHERS, INC.
014 B00AA12 8-26920
014 A00AA13 CS FIRST BOSTON (GLOBAL HIGH-YIELD ONLY)
014 B00AA13 8-xxxx
014 A00AA14 SOCIETE GENERALE(EMERGING OPPORTUNITIES ONLY)
014 B00AA14 8-xxxx
014 A00AA15 TRAVELERS DISTRIBUTION COMPANY
014 B00AA15 8-50244
014 A00AA16 SALOMON REINVESTMENT COMPANY, INC.
014 B00AA16 8-xxxx
014 A00AA17 CITICORP SECURITIES SERVICES, INC.
014 B00AA17 8-xxxx
014 A00AA18 CITICORP FINANCIAL SERVICES CORPORATION
014 B00AA18 8-xxxx
014 A00AA19 CITICORP INVESTMENT SERVICES
<PAGE>      PAGE  3
014 B00AA19 8-xxxx
014 A00AA20 CITICORP SECURITIES, INC.
014 B00AA20 8-xxxx
018  00AA00 Y
019 A00AA00 N
019 B00AA00    0
020 A000001 ROCHDALE SECURITIES CORP
020 B000001 13-3360814
020 C000001    313
020 A000002 GOLDMAN SACHS & CO.
020 B000002 13-5108880
020 C000002     93
020 A000003 MORGAN STANLEY & CO., INC.
020 B000003 13-2655998
020 C000003     88
020 A000004 PAINE WEBBER, INC.
020 B000004 13-2638166
020 C000004     84
020 A000005 PERSHING DIVISION OF DLJ
020 B000005 13-2741729
020 C000005     78
020 A000006 WARBURG DILLON READ
020 C000006     70
020 A000007 BEAR STEARNS & CO., INC.
020 B000007 13-3299429
020 C000007     62
020 A000008 MONTGOMERY SECURITIES
020 C000008     58
020 A000009 MERRILL LYNCH, PIERCE, FENNER & SMITH, INC.
020 B000009 13-5674085
020 C000009     49
020 A000010 BRIDGE TRADING
020 C000010     44
021  000000     1788
022 A000001 GOLDMAN SACHS & CO.
022 B000001 13-5108880
022 C000001    602026
022 D000001     77274
022 A000002 J.P. MORGAN & CO.
022 B000002 13-3224016
022 C000002    383360
022 D000002     35105
022 A000003 INVESTORS BANK & TRUST
022 C000003    137418
022 D000003     76595
022 A000004 MERRILL LYNCH, PIERCE, FENNER & SMITH, INC.
022 B000004 13-5674085
022 C000004    106836
022 D000004     59666
022 A000005 CHASE SECURITIES, INC.
022 B000005 13-3224016
<PAGE>      PAGE  4
022 C000005    148560
022 D000005     11033
022 A000006 CREDIT SUISSE FIRST BOSTON
022 B000006 13-5659485
022 C000006     79172
022 D000006     73292
022 A000007 BEAR STEARNS & CO., INC.
022 B000007 13-4946705
022 C000007     78285
022 D000007     65609
022 A000008 PERSHING DIVISION OF DLJ
022 B000008 13-2741729
022 C000008     76225
022 D000008     62302
022 A000009 MORGAN STANLEY & CO., INC.
022 B000009 13-2655998
022 C000009     81885
022 D000009     54108
022 A000010 WARBURG DILLON READ
022 C000010     32277
022 D000010     59184
023 C000000    2235610
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<PAGE>      PAGE  5
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<PAGE>      PAGE  6
080 A00AA00 NATIONAL UNION FIRE INSURANCE COMPANY
080 C00AA00     1700
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008 A000101 AMERICAN ODYSSEY FUNDS MANAGEMENT, INC.
008 B000101 A
008 C000101 801-43443
008 D010101 EAST BRUNSWICK
008 D020101 NJ
008 D030101 08816
008 D040101 1063
008 A000102 BANK OF IRELAND ASSET MANAGEMENT (U.S.) LTD.
008 B000102 S
008 C000102 801-29606
008 D010102 GREENWICH
008 D020102 CT
008 D030102 06830
015 A000101 INVESTORS BANK & TRUST COMPANY
015 B000101 C
015 C010101 BOSTON
015 C020101 MA
015 C030101 02117
015 C040101 9130
015 E010101 X
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<PAGE>      PAGE  7
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048 J020100 0.000
048 K010100   100000
048 K020100 0.550
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<PAGE>      PAGE  8
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063 B000100  0.0
066 A000100 Y
066 B000100 N
066 C000100 N
066 D000100 N
066 E000100 N
066 F000100 N
066 G000100 Y
067  000100 N
068 A000100 N
068 B000100 Y
069  000100 N
070 A010100 Y
070 A020100 N
070 B010100 Y
070 B020100 N
070 C010100 Y
070 C020100 N
070 D010100 Y
070 D020100 N
070 E010100 Y
070 E020100 N
070 F010100 Y
070 F020100 N
070 G010100 Y
070 G020100 N
070 H010100 Y
070 H020100 N
070 I010100 N
070 I020100 N
070 J010100 Y
070 J020100 Y
070 K010100 Y
070 K020100 N
070 L010100 Y
<PAGE>      PAGE  9
070 L020100 Y
070 M010100 Y
070 M020100 Y
070 N010100 Y
070 N020100 N
070 O010100 Y
070 O020100 N
070 P010100 N
070 P020100 N
070 Q010100 N
070 Q020100 N
070 R010100 Y
070 R020100 N
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<PAGE>      PAGE  10
073 A020100   0.0000
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074 N000100   389513
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074 R040100      838
074 S000100        0
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074 U020100        0
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074 V020100     0.00
074 W000100   0.0000
074 X000100        8
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075 A000100        0
075 B000100   324266
076  000100     0.00
008 A000201 AMERICAN ODYSSEY FUNDS MANAGEMENT, INC.
008 B000201 A
008 C000201 801-43443
008 D010201 EAST BRUNSWICK
008 D020201 NJ
008 D030201 08816
008 D040201 1063
008 A000202 CHARTWELL INVESTMENT PARTNERS
008 B000202 S
008 C000202 801-54124
008 D010202 BERWYN
008 D020202 PA
008 D030202 19312
008 D040202 2412
008 A000203 SG COWEN ASSET MANAGEMENT, INC.
<PAGE>      PAGE  11
008 B000203 S
008 C000203 801-7380
008 D010203 NEW YORK
008 D020203 NY
008 D030203 10005
008 D040203 3597
015 A000201 INVESTORS BANK & TRUST COMPANY
015 B000201 C
015 C010201 BOSTON
015 C020201 MA
015 C030201 02117
015 C040201 9130
015 E010201 X
028 A010200      2913
028 A020200         0
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028 B010200      1994
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045  000200 Y
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047  000200 Y
048  000200  0.000
048 A010200    50000
048 A020200 0.850
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048 B020200 0.725
048 C010200        0
<PAGE>      PAGE  12
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066 A000200 Y
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066 D000200 N
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066 F000200 N
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067  000200 N
068 A000200 N
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070 A010200 Y
070 A020200 N
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<PAGE>      PAGE  13
070 B020200 N
070 C010200 N
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070 D010200 Y
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070 E010200 N
070 E020200 N
070 F010200 Y
070 F020200 N
070 G010200 Y
070 G020200 N
070 H010200 Y
070 H020200 N
070 I010200 N
070 I020200 N
070 J010200 Y
070 J020200 N
070 K010200 Y
070 K020200 N
070 L010200 Y
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<PAGE>      PAGE  14
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<PAGE>      PAGE  15
074 X000200        8
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008 A000301 AMERICAN ODYSSEY FUNDS MANAGEMENT, INC.
008 B000301 A
008 C000301 801-43443
008 D010301 EAST BRUNSWICK
008 D020301 NJ
008 D030301 08816
008 D040301 1063
008 A000302 EQUINOX CAPITAL MANAGEMENT, LLC
008 B000302 S
008 C000302 801-34524
008 D010302 NEW YORK
008 D020302 NY
008 D030302 10022
015 A000301 INVESTORS BANK & TRUST COMPANY
015 B000301 C
015 C010301 BOSTON
015 C020301 MA
015 C030301 02117
015 C040301 9130
015 E010301 X
028 A010300      3857
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<PAGE>      PAGE  16
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048 K010300   100000
048 K020300 0.550
062 A000300 N
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<PAGE>      PAGE  17
066 E000300 N
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<PAGE>      PAGE  18
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073 A020300   0.0000
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073 C000300   0.0000
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<PAGE>      PAGE  19
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008 A000401 AMERICAN ODYSSEY FUNDS MANAGEMENT, INC.
008 B000401 A
008 C000401 801-43443
008 D010401 EAST BRUNSWICK
008 D020401 NJ
008 D030401 08816
008 D040401 1063
008 A000402 WESTERN ASSET MANAGEMENT COMPANY
008 B000402 S
008 C000402 801-08162
008 D010402 PASADENA
008 D020402 CA
008 D030402 91105
008 A000403 DELETE
015 A000401 INVESTORS BANK & TRUST COMPANY
015 B000401 C
015 C010401 BOSTON
015 C020401 MA
015 C030401 02117
015 C040401 9130
015 E010401 X
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<PAGE>      PAGE  20
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045  000400 Y
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<PAGE>      PAGE  21
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063 B000400 13.7
064 A000400 Y
064 B000400 N
066 A000400 N
067  000400 N
068 A000400 N
068 B000400 N
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070 A020400 N
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070 B020400 N
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070 C020400 Y
070 D010400 N
070 D020400 N
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070 E020400 Y
070 F010400 N
070 F020400 N
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070 G020400 Y
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070 H020400 N
070 I010400 N
070 I020400 N
070 J010400 Y
070 J020400 Y
070 K010400 Y
070 K020400 N
070 L010400 Y
070 L020400 Y
070 M010400 Y
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070 O020400 N
070 P010400 N
070 P020400 N
070 Q010400 N
070 Q020400 N
070 R010400 N
<PAGE>      PAGE  22
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<PAGE>      PAGE  23
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075 B000400   248911
076  000400     0.00
008 A000501 AMERICAN ODYSSEY FUNDS MANAGEMENT, INC.
008 B000501 A
008 C000501 801-43443
008 D010501 EAST BRUNSWICK
008 D020501 NJ
008 D030501 08816
008 D040501 1063
008 A000502 TRAVELERS ASSET MANAGEMENT INTERNATIONAL CORP
008 B000502 S
008 C000502 801-17003
008 D010502 HARTFORD
008 D020502 CT
008 D030502 06183
008 D040502 2030
015 A000501 INVESTORS BANK & TRUST COMPANY
015 B000501 C
015 C010501 BOSTON
015 C020501 MA
015 C030501 02117
015 C040501 9130
015 E010501 X
028 A010500      1480
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<PAGE>      PAGE  24
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045  000500 Y
046  000500 Y
047  000500 Y
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<PAGE>      PAGE  25
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062 I000500   1.9
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062 P000500  74.7
062 Q000500   0.0
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063 B000500  4.9
064 A000500 Y
064 B000500 N
066 A000500 N
067  000500 N
068 A000500 N
068 B000500 N
069  000500 N
070 A010500 Y
070 A020500 N
070 B010500 N
070 B020500 N
070 C010500 Y
070 C020500 N
070 D010500 N
070 D020500 N
070 E010500 Y
070 E020500 N
070 F010500 N
070 F020500 N
070 G010500 Y
070 G020500 N
070 H010500 N
070 H020500 N
070 I010500 N
070 I020500 N
070 J010500 Y
070 J020500 Y
070 K010500 Y
070 K020500 N
070 L010500 Y
070 L020500 Y
070 M010500 Y
070 M020500 N
<PAGE>      PAGE  26
070 N010500 Y
070 N020500 N
070 O010500 Y
070 O020500 N
070 P010500 N
070 P020500 N
070 Q010500 N
070 Q020500 N
070 R010500 N
070 R020500 N
071 A000500    403760
071 B000500    388087
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072 A000500 12
072 B000500     8138
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073 A010500   0.5875
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073 C000500   0.0000
<PAGE>      PAGE  27
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074 R030500        0
074 R040500      100
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075 A000500        0
075 B000500   126884
076  000500     0.00
008 A000601 AMERICAN ODYSSEY FUNDS MANAGEMENT, INC.
008 B000601 A
008 C000601 801-43443
008 D010601 EAST BRUNSWICK
008 D020601 NJ
008 D030601 08816
008 D040601 1063
008 A000602 CREDIT SUISSE ASSET MANAGEMENT
008 B000602 S
008 C000602 801-37170
008 D010602 NEW YORK
008 D020602 NY
008 D030602 10017
015 A000601 INVESTORS BANK & TRUST COMPANY
015 B000601 C
015 C010601 BOSTON
015 C020601 MA
015 C030601 02117
<PAGE>      PAGE  28
015 C040601 9130
015 E010601 X
028 A010600      1181
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045  000600 Y
046  000600 Y
047  000600 Y
048  000600  0.675
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<PAGE>      PAGE  29
048 I010600        0
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064 A000600 Y
064 B000600 Y
065  000600 N
066 A000600 N
067  000600 N
068 A000600 N
068 B000600 N
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070 A020600 N
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070 B020600 N
070 C010600 Y
070 C020600 N
070 D010600 Y
070 D020600 N
070 E010600 Y
070 E020600 N
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070 F020600 N
070 G010600 Y
070 G020600 N
070 H010600 Y
070 H020600 N
070 I010600 N
<PAGE>      PAGE  30
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070 J010600 Y
070 J020600 Y
070 K010600 Y
070 K020600 N
070 L010600 Y
070 L020600 Y
070 M010600 Y
070 M020600 Y
070 N010600 Y
070 N020600 N
070 O010600 Y
070 O020600 N
070 P010600 N
070 P020600 N
070 Q010600 N
070 Q020600 N
070 R010600 N
070 R020600 N
071 A000600     46524
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<PAGE>      PAGE  31
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076  000600     0.00
SIGNATURE   PAUL S. FEINBERG
TITLE       V.P. & SECRETARY



<TABLE> <S> <C>

<ARTICLE> 6
<LEGEND>
This schedule contains summary financial information
extracted from American Odyssey Funds, Inc.
form N-SAR for the period ended December 31, 1999
and is qualified in its entirety by reference to
such financial statements.
</LEGEND>
<SERIES>
   <NUMBER> 1
   <NAME>   American Odyssey International Equity Fund

<S>                             <C>
<PERIOD-TYPE>                   12-MOS
<FISCAL-YEAR-END>                          DEC-31-1999
<PERIOD-END>                               Dec-31-1999
<INVESTMENTS-AT-COST>                     242,368,404
<INVESTMENTS-AT-VALUE>                    382,674,318
<RECEIVABLES>                                 544,284
<ASSETS-OTHER>                              6,294,530
<OTHER-ITEMS-ASSETS>                                0
<TOTAL-ASSETS>                            389,513,132
<PAYABLE-FOR-SECURITIES>                            0
<SENIOR-LONG-TERM-DEBT>                             0
<OTHER-ITEMS-LIABILITIES>                   1,020,810
<TOTAL-LIABILITIES>                         1,020,810
<SENIOR-EQUITY>                                     0
<PAID-IN-CAPITAL-COMMON>                  231,701,610
<SHARES-COMMON-STOCK>                      17,396,094
<SHARES-COMMON-PRIOR>                      17,809,092
<ACCUMULATED-NII-CURRENT>                   3,371,638
<OVERDISTRIBUTION-NII>                              0
<ACCUMULATED-NET-GAINS>                    14,098,563
<OVERDISTRIBUTION-GAINS>                            0
<ACCUM-APPREC-OR-DEPREC>                  139,320,511
<NET-ASSETS>                              388,492,322
<DIVIDEND-INCOME>                           5,044,573
<INTEREST-INCOME>                             206,432
<OTHER-INCOME>                                      0
<EXPENSES-NET>                              2,312,122
<NET-INVESTMENT-INCOME>                     2,938,883
<REALIZED-GAINS-CURRENT>                   19,987,247
<APPREC-INCREASE-CURRENT>                  73,581,147
<NET-CHANGE-FROM-OPS>                      96,507,277
<EQUALIZATION>                                      0
<DISTRIBUTIONS-OF-INCOME>                           0
<DISTRIBUTIONS-OF-GAINS>                            0
<DISTRIBUTIONS-OTHER>                               0
<NUMBER-OF-SHARES-SOLD>                     2,008,249
<NUMBER-OF-SHARES-REDEEMED>                 2,421,247
<SHARES-REINVESTED>                                 0
<NET-CHANGE-IN-ASSETS>                     17,396,094
<ACCUMULATED-NII-PRIOR>                       797,921
<ACCUMULATED-GAINS-PRIOR>                           0
<OVERDISTRIB-NII-PRIOR>                             0
<OVERDIST-NET-GAINS-PRIOR>                  6,253,851
<GROSS-ADVISORY-FEES>                       1,907,212
<INTEREST-EXPENSE>                                  0
<GROSS-EXPENSE>                             2,344,065
<AVERAGE-NET-ASSETS>                      324,038,163
<PER-SHARE-NAV-BEGIN>                           16.85
<PER-SHARE-NII>                                  0.17
<PER-SHARE-GAIN-APPREC>                          5.31
<PER-SHARE-DIVIDEND>                             0.00
<PER-SHARE-DISTRIBUTIONS>                        0.00
<RETURNS-OF-CAPITAL>                                0
<PER-SHARE-NAV-END>                             22.33
<EXPENSE-RATIO>                                  0.71


</TABLE>

<TABLE> <S> <C>

<ARTICLE> 6
<LEGEND>
This schedule contains summary financial information
extracted from American Odyssey Funds, Inc.
form N-SAR for the period ended December 31, 1999
and is qualified in its entirety by reference to
such financial statements.
</LEGEND>
<SERIES>
   <NUMBER> 2
   <NAME>   American Odyssey Emerging Opportunities Fu

<S>                             <C>
<PERIOD-TYPE>                   12-MOS
<FISCAL-YEAR-END>                          DEC-31-1999
<PERIOD-END>                               Dec-31-1999
<INVESTMENTS-AT-COST>                     297,137,847
<INVESTMENTS-AT-VALUE>                    369,840,596
<RECEIVABLES>                               4,586,774
<ASSETS-OTHER>                              8,069,976
<OTHER-ITEMS-ASSETS>                                0
<TOTAL-ASSETS>                            382,497,346
<PAYABLE-FOR-SECURITIES>                    8,173,484
<SENIOR-LONG-TERM-DEBT>                             0
<OTHER-ITEMS-LIABILITIES>                     685,534
<TOTAL-LIABILITIES>                         8,859,018
<SENIOR-EQUITY>                                     0
<PAID-IN-CAPITAL-COMMON>                  286,449,376
<SHARES-COMMON-STOCK>                     227,587,014
<SHARES-COMMON-PRIOR>                      20,493,456
<ACCUMULATED-NII-CURRENT>                      55,097
<OVERDISTRIBUTION-NII>                              0
<ACCUMULATED-NET-GAINS>                    14,431,106
<OVERDISTRIBUTION-GAINS>                            0
<ACCUM-APPREC-OR-DEPREC>                   72,702,749
<NET-ASSETS>                              373,638,328
<DIVIDEND-INCOME>                           1,175,460
<INTEREST-INCOME>                             350,830
<OTHER-INCOME>                                      0
<EXPENSES-NET>                              2,466,322
<NET-INVESTMENT-INCOME>                      (940,032)
<REALIZED-GAINS-CURRENT>                   17,511,829
<APPREC-INCREASE-CURRENT>                  84,620,566
<NET-CHANGE-FROM-OPS>                     101,192,363
<EQUALIZATION>                                      0
<DISTRIBUTIONS-OF-INCOME>                           0
<DISTRIBUTIONS-OF-GAINS>                   25,671,500
<DISTRIBUTIONS-OTHER>                               0
<NUMBER-OF-SHARES-SOLD>                     2,777,931
<NUMBER-OF-SHARES-REDEEMED>                 2,415,685
<SHARES-REINVESTED>                         1,903,002
<NET-CHANGE-IN-ASSETS>                    105,308,523
<ACCUMULATED-NII-PRIOR>                             0
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<OVERDISTRIB-NII-PRIOR>                             0
<OVERDIST-NET-GAINS-PRIOR>                          0
<GROSS-ADVISORY-FEES>                       2,230,930
<INTEREST-EXPENSE>                                  0
<GROSS-EXPENSE>                             2,566,815
<AVERAGE-NET-ASSETS>                      296,290,274
<PER-SHARE-NAV-BEGIN>                           13.09
<PER-SHARE-NII>                                 (0.04)
<PER-SHARE-GAIN-APPREC>                          4.58
<PER-SHARE-DIVIDEND>                             0.00
<PER-SHARE-DISTRIBUTIONS>                        1.21
<RETURNS-OF-CAPITAL>                                0
<PER-SHARE-NAV-END>                             16.42
<EXPENSE-RATIO>                                  0.83


</TABLE>

<TABLE> <S> <C>

<ARTICLE> 6
<LEGEND>
This schedule contains summary financial information
extracted from American Odyssey Funds, Inc.
form N-SAR for the period ended December 31, 1999
and is qualified in its entirety by reference to
such financial statements.
</LEGEND>
<SERIES>
   <NUMBER> 3
   <NAME>   American Odyssey Core Equity Fund

<S>                             <C>
<PERIOD-TYPE>                   12-MOS
<FISCAL-YEAR-END>                          DEC-31-1999
<PERIOD-END>                               Dec-31-1999
<INVESTMENTS-AT-COST>                     378,516,923
<INVESTMENTS-AT-VALUE>                    455,017,013
<RECEIVABLES>                               1,085,991
<ASSETS-OTHER>                             16,169,880
<OTHER-ITEMS-ASSETS>                                0
<TOTAL-ASSETS>                            472,272,884
<PAYABLE-FOR-SECURITIES>                    1,164,664
<SENIOR-LONG-TERM-DEBT>                             0
<OTHER-ITEMS-LIABILITIES>                     690,855
<TOTAL-LIABILITIES>                         1,855,519
<SENIOR-EQUITY>                                     0
<PAID-IN-CAPITAL-COMMON>                  367,008,139
<SHARES-COMMON-STOCK>                      26,709,805
<SHARES-COMMON-PRIOR>                      22,953,325
<ACCUMULATED-NII-CURRENT>                   5,738,472
<OVERDISTRIBUTION-NII>                              0
<ACCUMULATED-NET-GAINS>                    21,170,664
<OVERDISTRIBUTION-GAINS>                            0
<ACCUM-APPREC-OR-DEPREC>                   76,500,090
<NET-ASSETS>                              470,417,365
<DIVIDEND-INCOME>                           8,440,784
<INTEREST-INCOME>                             273,015
<OTHER-INCOME>                                      0
<EXPENSES-NET>                              2,974,050
<NET-INVESTMENT-INCOME>                     5,739,749
<REALIZED-GAINS-CURRENT>                   21,659,887
<APPREC-INCREASE-CURRENT>                 (27,761,775)
<NET-CHANGE-FROM-OPS>                        (362,139)
<EQUALIZATION>                                      0
<DISTRIBUTIONS-OF-INCOME>                   6,078,603
<DISTRIBUTIONS-OF-GAINS>                   65,203,555
<DISTRIBUTIONS-OTHER>                               0
<NUMBER-OF-SHARES-SOLD>                     2,346,314
<NUMBER-OF-SHARES-REDEEMED>                 2,355,400
<SHARES-REINVESTED>                         3,765,566
<NET-CHANGE-IN-ASSETS>                     (2,535,897)
<ACCUMULATED-NII-PRIOR>                     6,077,406
<ACCUMULATED-GAINS-PRIOR>                  64,714,251
<OVERDISTRIB-NII-PRIOR>                             0
<OVERDIST-NET-GAINS-PRIOR>                          0
<GROSS-ADVISORY-FEES>                       2,695,731
<INTEREST-EXPENSE>                                  0
<GROSS-EXPENSE>                             3,091,237
<AVERAGE-NET-ASSETS>                      481,042,123
<PER-SHARE-NAV-BEGIN>                           20.61
<PER-SHARE-NII>                                  0.22
<PER-SHARE-GAIN-APPREC>                         (0.06)
<PER-SHARE-DIVIDEND>                             0.27
<PER-SHARE-DISTRIBUTIONS>                        2.89
<RETURNS-OF-CAPITAL>                                0
<PER-SHARE-NAV-END>                             17.61
<EXPENSE-RATIO>                                  0.62


</TABLE>

<TABLE> <S> <C>

<ARTICLE> 6
<LEGEND>
This schedule contains summary financial information
extracted from American Odyssey Funds, Inc.
form N-SAR for the period ended December 31, 1999
and is qualified in its entirety by reference to
such financial statements.
</LEGEND>
<SERIES>
   <NUMBER> 4
   <NAME>   American Odyssey Long-Term Bond Fund

<S>                             <C>
<PERIOD-TYPE>                   12-MOS
<FISCAL-YEAR-END>                          DEC-31-1999
<PERIOD-END>                               Dec-31-1999
<INVESTMENTS-AT-COST>                     250,106,091
<INVESTMENTS-AT-VALUE>                    239,132,697
<RECEIVABLES>                               2,749,207
<ASSETS-OTHER>                             17,710,386
<OTHER-ITEMS-ASSETS>                                0
<TOTAL-ASSETS>                            259,592,290
<PAYABLE-FOR-SECURITIES>                            0
<SENIOR-LONG-TERM-DEBT>                             0
<OTHER-ITEMS-LIABILITIES>                   5,224,702
<TOTAL-LIABILITIES>                         5,224,702
<SENIOR-EQUITY>                                     0
<PAID-IN-CAPITAL-COMMON>                  256,701,154
<SHARES-COMMON-STOCK>                      24,991,095
<SHARES-COMMON-PRIOR>                      22,145,289
<ACCUMULATED-NII-CURRENT>                  16,204,242
<OVERDISTRIBUTION-NII>                              0
<ACCUMULATED-NET-GAINS>                             0
<OVERDISTRIBUTION-GAINS>                    7,349,889
<ACCUM-APPREC-OR-DEPREC>                  (11,187,937)
<NET-ASSETS>                              254,367,570
<DIVIDEND-INCOME>                              35,000
<INTEREST-INCOME>                          17,419,117
<OTHER-INCOME>                                      0
<EXPENSES-NET>                              1,488,286
<NET-INVESTMENT-INCOME>                    15,965,831
<REALIZED-GAINS-CURRENT>                   (7,494,141)
<APPREC-INCREASE-CURRENT>                 (15,331,895)
<NET-CHANGE-FROM-OPS>                      (6,860,205)
<EQUALIZATION>                                      0
<DISTRIBUTIONS-OF-INCOME>                  14,567,381
<DISTRIBUTIONS-OF-GAINS>                    6,872,189
<DISTRIBUTIONS-OTHER>                               0
<NUMBER-OF-SHARES-SOLD>                     3,132,985
<NUMBER-OF-SHARES-REDEEMED>                 2,420,469
<SHARES-REINVESTED>                         2,133,290
<NET-CHANGE-IN-ASSETS>                    (11,520,037)
<ACCUMULATED-NII-PRIOR>                    14,565,934
<ACCUMULATED-GAINS-PRIOR>                   7,256,299
<OVERDISTRIB-NII-PRIOR>                             0
<OVERDIST-NET-GAINS-PRIOR>                          0
<GROSS-ADVISORY-FEES>                       1,244,205
<INTEREST-EXPENSE>                                  0
<GROSS-EXPENSE>                             1,488,286
<AVERAGE-NET-ASSETS>                      248,913,084
<PER-SHARE-NAV-BEGIN>                           11.49
<PER-SHARE-NII>                                  0.65
<PER-SHARE-GAIN-APPREC>                         (0.98)
<PER-SHARE-DIVIDEND>                             0.67
<PER-SHARE-DISTRIBUTIONS>                        0.31
<RETURNS-OF-CAPITAL>                                0
<PER-SHARE-NAV-END>                             10.18
<EXPENSE-RATIO>                                  0.60


</TABLE>

<TABLE> <S> <C>

<ARTICLE> 6
<LEGEND>
This schedule contains summary financial information
extracted from American Odyssey Funds, Inc.
form N-SAR for the period ended December 31, 1999
and is qualified in its entirety by reference to
such financial statements.
</LEGEND>
<SERIES>
   <NUMBER> 5
   <NAME>   American Odyssey Intermediate-Term Bond Fu

<S>                             <C>
<PERIOD-TYPE>                   12-MOS
<FISCAL-YEAR-END>                          DEC-31-1999
<PERIOD-END>                               Dec-31-1999
<INVESTMENTS-AT-COST>                     131,342,510
<INVESTMENTS-AT-VALUE>                    128,916,305
<RECEIVABLES>                               2,358,718
<ASSETS-OTHER>                                  1,583
<OTHER-ITEMS-ASSETS>                                0
<TOTAL-ASSETS>                            131,276,606
<PAYABLE-FOR-SECURITIES>                            0
<SENIOR-LONG-TERM-DEBT>                             0
<OTHER-ITEMS-LIABILITIES>                     153,329
<TOTAL-LIABILITIES>                           153,329
<SENIOR-EQUITY>                                     0
<PAID-IN-CAPITAL-COMMON>                  129,218,877
<SHARES-COMMON-STOCK>                      12,658,199
<SHARES-COMMON-PRIOR>                      11,356,645
<ACCUMULATED-NII-CURRENT>                   7,390,343
<OVERDISTRIBUTION-NII>                              0
<ACCUMULATED-NET-GAINS>                             0
<OVERDISTRIBUTION-GAINS>                    3,059,738
<ACCUM-APPREC-OR-DEPREC>                   (2,426,205)
<NET-ASSETS>                              131,123,277
<DIVIDEND-INCOME>                                   0
<INTEREST-INCOME>                           8,138,446
<OTHER-INCOME>                                      0
<EXPENSES-NET>                                747,375
<NET-INVESTMENT-INCOME>                     7,391,071
<REALIZED-GAINS-CURRENT>                   (3,059,738)
<APPREC-INCREASE-CURRENT>                  (2,404,548)
<NET-CHANGE-FROM-OPS>                       1,926,785
<EQUALIZATION>                                      0
<DISTRIBUTIONS-OF-INCOME>                   6,579,835
<DISTRIBUTIONS-OF-GAINS>                    3,746,306
<DISTRIBUTIONS-OTHER>                               0
<NUMBER-OF-SHARES-SOLD>                     1,678,567
<NUMBER-OF-SHARES-REDEEMED>                 1,389,380
<SHARES-REINVESTED>                         1,012,367
<NET-CHANGE-IN-ASSETS>                      4,764,754
<ACCUMULATED-NII-PRIOR>                     6,579,802
<ACCUMULATED-GAINS-PRIOR>                   3,745,610
<OVERDISTRIB-NII-PRIOR>                             0
<OVERDIST-NET-GAINS-PRIOR>                          0
<GROSS-ADVISORY-FEES>                         620,940
<INTEREST-EXPENSE>                                  0
<GROSS-EXPENSE>                               747,375
<AVERAGE-NET-ASSETS>                      126,875,693
<PER-SHARE-NAV-BEGIN>                           11.13
<PER-SHARE-NII>                                  0.59
<PER-SHARE-GAIN-APPREC>                         (0.44)
<PER-SHARE-DIVIDEND>                             0.59
<PER-SHARE-DISTRIBUTIONS>                        0.33
<RETURNS-OF-CAPITAL>                                0
<PER-SHARE-NAV-END>                             10.36
<EXPENSE-RATIO>                                  0.59


</TABLE>

<TABLE> <S> <C>

<ARTICLE> 6
<LEGEND>
This schedule contains summary financial information
extracted from American Odyssey Funds, Inc.
form N-SAR for the period ended December 31, 1999
and is qualified in its entirety by reference to
such financial statements.
</LEGEND>
<SERIES>
   <NUMBER> 6
   <NAME>   American Odyssey Global High-Yield Bond Fu

<S>                             <C>
<PERIOD-TYPE>                   12-MOS
<FISCAL-YEAR-END>                          DEC-31-1999
<PERIOD-END>                               Dec-31-1999
<INVESTMENTS-AT-COST>                      96,722,187
<INVESTMENTS-AT-VALUE>                     92,774,210
<RECEIVABLES>                               2,173,777
<ASSETS-OTHER>                              1,869,566
<OTHER-ITEMS-ASSETS>                                0
<TOTAL-ASSETS>                             96,817,553
<PAYABLE-FOR-SECURITIES>                            0
<SENIOR-LONG-TERM-DEBT>                             0
<OTHER-ITEMS-LIABILITIES>                     195,889
<TOTAL-LIABILITIES>                           195,889
<SENIOR-EQUITY>                                     0
<PAID-IN-CAPITAL-COMMON>                   96,805,934
<SHARES-COMMON-STOCK>                       9,382,126
<SHARES-COMMON-PRIOR>                       8,265,528
<ACCUMULATED-NII-CURRENT>                   9,124,401
<OVERDISTRIBUTION-NII>                              0
<ACCUMULATED-NET-GAINS>                             0
<OVERDISTRIBUTION-GAINS>                    5,360,694
<ACCUM-APPREC-OR-DEPREC>                   (3,947,977)
<NET-ASSETS>                               96,621,664
<DIVIDEND-INCOME>                                   0
<INTEREST-INCOME>                           9,803,352
<OTHER-INCOME>                                      0
<EXPENSES-NET>                                733,709
<NET-INVESTMENT-INCOME>                     9,069,643
<REALIZED-GAINS-CURRENT>                     (161,844)
<APPREC-INCREASE-CURRENT>                     137,045
<NET-CHANGE-FROM-OPS>                       9,044,844
<EQUALIZATION>                                      0
<DISTRIBUTIONS-OF-INCOME>                   5,442,107
<DISTRIBUTIONS-OF-GAINS>                            0
<DISTRIBUTIONS-OTHER>                               0
<NUMBER-OF-SHARES-SOLD>                     1,172,084
<NUMBER-OF-SHARES-REDEEMED>                   610,237
<SHARES-REINVESTED>                           554,751
<NET-CHANGE-IN-ASSETS>                     14,613,592
<ACCUMULATED-NII-PRIOR>                     5,442,468
<ACCUMULATED-GAINS-PRIOR>                           0
<OVERDISTRIB-NII-PRIOR>                             0
<OVERDIST-NET-GAINS-PRIOR>                  5,117,260
<GROSS-ADVISORY-FEES>                         597,092
<INTEREST-EXPENSE>                                  0
<GROSS-EXPENSE>                               733,709
<AVERAGE-NET-ASSETS>                       88,458,113
<PER-SHARE-NAV-BEGIN>                            9.92
<PER-SHARE-NII>                                  0.96
<PER-SHARE-GAIN-APPREC>                          0.07
<PER-SHARE-DIVIDEND>                             0.65
<PER-SHARE-DISTRIBUTIONS>                        0.00
<RETURNS-OF-CAPITAL>                                0
<PER-SHARE-NAV-END>                             10.30
<EXPENSE-RATIO>                                  0.83


</TABLE>

Page 1








REPORT OF INDEPENDENT ACCOUNTANTS
TO ACCOMPANY FORM N-SAR


To the Shareholders and
Board of Directors of
American Odyssey Funds, Inc.

In planning and  performing  our audit of the  financial  statements of American
Odyssey  Funds,  Inc. for the year ended  December 31, 1999, we  considered  its
internal control,  including control activities for safeguarding securities,  in
order to determine our auditing  procedures  for the purpose of  expressing  our
opinion on the financial  statements and to comply with the requirements of Form
N-SAR, not to provide assurance on internal control.

The management of American  Odyssey Funds,  Inc. is responsible for establishing
and maintaining internal control. In fulfilling this  responsibility,  estimates
and  judgments by  management  are required to assess the expected  benefits and
related  costs of controls.  Generally,  controls  that are relevant to an audit
pertain to the entity's objective of preparing financial statements for external
purposes  that are  fairly  presented  in  conformity  with  generally  accepted
accounting principles. Those controls include the safeguarding of assets against
unauthorized acquisition, use or disposition.

Because of inherent  limitations in internal  control,  errors or irregularities
may occur and not be detected.  Also,  projection of any  evaluation of internal
control to future periods is subject to the risks that it may become  inadequate
because of changes in  conditions  or that the  effectiveness  of the design and
operation may deteriorate.

Our consideration of internal control would not necessarily disclose all matters
in  internal   control  that  might  be  material   weaknesses  under  standards
established  by the  American  Institute  of  Certified  Public  Accountants.  A
material weakness is a condition in which the design or operation of one or more
of the internal control components does not reduce to a relatively low level the
risk that errors or irregularities in amounts that would be material in relation
to the financial statements being audited may occur and not be detected within a
timely  period by employees in the normal course of  performing  their  assigned
functions.  However,  we noted no matters  involving  internal  control  and its
operation,  including controls for safeguarding securities,  that we consider to
be material weaknesses as defined above.

This report is intended solely for the information and use of management,  the
Board of Directors of American  Odyssey Funds,  Inc., and the Securities and
Exchange Commission and is not intended to be and should not be used by anyone
other than these specified parties.
Boston, Massachusetts
February 4, 2000



                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                   Transactions effected pursuant to Rule 10f-3

Transaction # 1: Emerging Opportunities Fund, purchase of Triquint Semiconductor

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    Montgomery. Montgomery  was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

    S.G. Cowen  was the affiliated underwriter of the Fund and the
    syndicate included various other underwriters.

3. Terms of the transaction.

Emerging Opportunities Fund, managed by Chartwell Investment Partners, purchased
2,500 Shares of Triquint Semiconductor, a company in continuous operation for 3+
years, in an ,initial public offering at the offering price of $43.625 per share
on July 13, 1999. The underwriting  selling concession was 3.09%. The percentage
of the offering purchased by the Emerging  Opportunities Fund was 0.0658% of the
total offering.  The security purchased was part of an issue registered with the
Securities  and  Exchange   Commission  and  was  part  of  a  firm   commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made. .

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.






                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                        Transactions effected pursuant to Rule 10f-3

Transaction # 2: Emerging Opportunities Fund, purchase of  Ravisent Technologies

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    Volpe. Volpe was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

    S.G. Cowen was the affiliated underwriter of the Fund and the
    syndicate included various other underwriters.

3. Terms of the transaction.

Emerging Opportunities Fund, managed by Chartwell Investment Partners, purchased
200 Shares of Ravisent  Technologies,  a company in continuous  operation for 3+
years,  in an initial public  offering at the offering price of $12.00 per share
on July 15, 1999. The underwriting  selling concession was 4.25%. The percentage
of the offering  purchased by the Emerging  Opportunities Fund was 0.004% of the
total offering.  The security purchased was part of an issue registered with the
Securities  and  Exchange   Commission  and  was  part  of  a  firm   commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made. .

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                       Transactions effected pursuant to Rule 10f-3

Transaction # 3: Emerging Opportunities Fund, purchase of Ravisent Technologies

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    Bear Stearns. Bear Stearns was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   S.G. Cowen was the affiliated underwriter of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Emerging Opportunities Fund, managed by Chartwell Investment Partners, purchased
14,700 Shares of Ravisent Technologies, a company in continuous operation for 3+
years,  in an initial public  offering at the offering price of $12.00 per share
on July 15, 1999. The underwriting  selling concession was 4.25%. The percentage
of the offering  purchased by the Emerging  Opportunities Fund was 0.294% of the
total offering.  The security purchased was part of an issue registered with the
Securities  and  Exchange   Commission  and  was  part  of  a  firm   commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made. .

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                  Transactions effected pursuant to Rule 10f-3

Transaction # 4: Emerging Opportunities Fund, purchase of  Paradyne Network,Inc.

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

   Robert Stephens. Robert Stephens was not an affiliated underwriter
   of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon Smith Barney and Robinson-Humphrey  were the affiliated  underwriters
   of the Fund and the syndicate included various other underwriters.

3. Terms of the transaction.

Emerging Opportunities Fund, managed by Chartwell Investment Partners, purchased
4,500 Shares of Paradyne Network, Inc., a company in continuous operation for 3+
years,  in an initial public  offering at the offering price of $17.00 per share
on July 16, 1999. The underwriting  selling concession was 4.18%. The percentage
of the offering purchased by the Emerging  Opportunities Fund was 0.1125% of the
total offering.  The security purchased was part of an issue registered with the
Securities  and  Exchange   Commission  and  was  part  of  a  firm   commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made. .

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                 Transactions effected pursuant to Rule 10f-3

Transaction # 5: Emerging Opportunities Fund, purchase of SFX Entertainment

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

      Lehman Bros. Lehman Bros. was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

    S.G. Cowen was the affiliated underwriter of the Fund and the
    syndicate included various other underwriters.

3. Terms of the transaction.

Emerging Opportunities Fund, managed by Chartwell Investment Partners, purchased
11,000 Shares of SFX  Entertainment,  a company in  continuous  operation for 3+
years,  in an initial public  offering at the offering price of $41.00 per share
on  August  17,  1999.  The  underwriting  selling  concession  was  2.24%.  The
percentage  of the offering  purchased by the  Emerging  Opportunities  Fund was
0.1467%  of the total  offering.  The  security  purchased  was part of an issue
registered  with the Securities  and Exchange  Commission and was part of a firm
commitment underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made. .

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                  Transactions effected pursuant to Rule 10f-3

Transaction # 6: Emerging Opportunities Fund, purchase of LaBranche & Co.

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

      DLJ. DLJ was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Emerging Opportunities Fund, managed by Chartwell Investment Partners, purchased
5,000 Shares of LaBranche & Co., a company in continuous operation for 3+ years,
in an  initial  public  offering  at the  offering  price of $14.00 per share on
August 19, 1999. The underwriting  selling  concession was 4.21%. The percentage
of the offering purchased by the Emerging  Opportunities Fund was 0.0476% of the
total offering.  The security purchased was part of an issue registered with the
Securities  and  Exchange   Commission  and  was  part  of  a  firm   commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made. .

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                    Transactions effected pursuant to Rule 10f-3

Transaction # 7: Emerging Opportunities Fund, purchase of LaBranche & Co.

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    ABN Amro. ABN Amro was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Emerging Opportunities Fund, managed by Chartwell Investment Partners, purchased
2,000 Shares of LaBranche & Co., a company in continuous operation for 3+ years,
in an  initial  public  offering  at the  offering  price of $14.00 per share on
August 19, 1999. The underwriting  selling  concession was 4.21%. The percentage
of the offering purchased by the Emerging  Opportunities Fund was 0.0190% of the
total offering.  The security purchased was part of an issue registered with the
Securities  and  Exchange   Commission  and  was  part  of  a  firm   commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made. .

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                           Transactions effected pursuant to Rule 10f-3

Transaction # 8: Long Term Bond Fund, purchase of Allied Waste - 144A,
10.00%, due 8/01/09

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    Donaldson, Lufkin & Jenrette. Donaldson, Lufkin & Jenrette was not an
    affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Long Term Bond Fund,  managed by Western Asset  Management,  purchased  $239,000
principal face of Allied Waste, a company in continuous  operation for 3+ years,
in an initial public  offering at the offering price of $99.690 per unit on July
30, 1999. The underwriting spread paid was 3.00%. The percentage of the offering
purchased  by the Long Term Bond Fund was  0.0120%  of the total  offering.  The
security  purchased  was part of an issue  registered  with the  Securities  and
Exchange Commission and was part of a firm commitment underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.






                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                           Transactions effected pursuant to Rule 10f-3

Transaction # 9: Long Term Bond Fund, purchase of Crown Castle
International Corp. - 144A, 9.50%, due 8/11/11

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    Goldman Sachs. Goldman Sachs was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Long Term Bond Fund,  managed by Western Asset  Management,  purchased  $148,000
principal  face of Crown Castle  International  Corp.,  a company in  continuous
operation for 3+ years,  in an initial public  offering at the offering price of
$100.00 per unit on August 3, 1999. The underwriting  spread paid was 2.50%. The
percentage  of the offering  purchased by the Long Term Bond Fund was 0.1184% of
the total offering.  The security purchased was part of an issue registered with
the  Securities  and  Exchange  Commission  and was  part  of a firm  commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.






                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                           Transactions effected pursuant to Rule 10f-3

Transaction # 10: Long Term Bond Fund, purchase of  Worldwide Fiber - 144A,
12.00%, due 8/01/09

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    Donaldson, Lufkin & Jenrette. Donaldson, Lufkin & Jenrette was not an
    affiliated underwriter
    of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Long Term Bond Fund,  managed by Western Asset  Management,  purchased  $100,000
principal  face of Worldwide  Fiber,  a company in  continuous  operation for 3+
years,  in an initial public  offering at the offering price of $100.00 per unit
on July 28, 1999. The underwriting  spread paid was 3.00%. The percentage of the
offering purchased by the Long Term Bond Fund was 0.0200% of the total offering.
The security  purchased was part of an issue  registered with the Securities and
Exchange Commission and was part of a firm commitment underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.





                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                           Transactions effected pursuant to Rule 10f-3

Transaction # 11: Intermediate-Term Bond Fund, purchase of Safeway,
7.50%, due 9/15/09

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

   Morgan Stanley. Morgan Stanley was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Intermediate-Term   Bond   Fund,   managed   by   Travelers   Asset   Management
International,  purchased  $4,800,000  principal  face of Safeway,  a company in
continuous operation for 3+ years, in an initial public offering at the offering
price of $99.418 per unit on September 8, 1999. The underwriting spread paid was
0.65%. The percentage of the offering  purchased by the  Intermediate-Term  Bond
Fund was 0.960% of the total  offering.  The security  purchased  was part of an
issue  registered with the Securities and Exchange  Commission and was part of a
firm commitment underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.




                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                           Transactions effected pursuant to Rule 10f-3

Transaction # 12: Global High Yield Bond Fund, purchase of Airgate PCS.,
13.50%, due 10/01/09

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

 Donaldson, Lufkin & Jenrette. Donaldson, Lufkin & Jenrette was not an
 affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Credit Suisse First Boston was the affiliated underwriter of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Global  High  Yield  Bond  Fund,  managed  by Credit  Suisse  Asset  Management,
purchased  $150,000  principal  face of Airgate  PCS,  a company  in  continuous
operation for 3+ years,  in an initial public  offering at the offering price of
$52.019 per unit on September 27, 1999. The underwriting  spread paid was 3.50%.
The percentage of the offering  purchased by the Global High Yield Bond Fund was
 .0500%  of the  total  offering.  The  security  purchased  was part of an issue
registered  with the Securities  and Exchange  Commission and was part of a firm
commitment underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.




                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                           Transactions effected pursuant to Rule 10f-3

Transaction # 13: Global High Yield Bond Fund, purchase of Holley Performance
Products - 144A, 12.25%, due 9/15/07

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

 Goldman Sachs. Goldman Sachs was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Global  High  Yield  Bond  Fund,  managed  by Credit  Suisse  Asset  Management,
purchased $250,000 principal face of Holley Performance  Products,  a company in
continuous operation for 3+ years, in an initial public offering at the offering
price of $96.346 per unit on September 15, 1999.  The  underwriting  spread paid
was 3.65%.  The  percentage  of the offering  purchased by the Global High Yield
Bond Fund was .1667% of the total offering.  The security  purchased was part of
an issue registered with the Securities and Exchange  Commission and was part of
a firm commitment underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                           Transactions effected pursuant to Rule 10f-3

Transaction # 14: Global High Yield Bond Fund, purchase of United Pan-Europe
Communications, 12.50%, due 8/01/09

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

 Donaldson, Lufkin & Jenrette.  Donaldson, Lufkin & Jenrette was not an
 affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

 Credit  Suisse  First  Boston and  Salomon  Smith  Barney  were the  affiliated
  underwriters   of  the  Fund  and  the   syndicate   included   various  other
  underwriters.

3. Terms of the transaction.

Global  High  Yield  Bond  Fund,  managed  by Credit  Suisse  Asset  Management,
purchased $450,000 principal face of United Pan-Europe Communications, a company
in  continuous  operation  for 3+ years,  in an initial  public  offering at the
offering  price of $54.524 per unit on July 27, 1999.  The  underwriting  spread
paid was 3.68%.  The  percentage  of the  offering  purchased by the Global High
Yield Bond Fund was .06122% of the total  offering.  The security  purchased was
part of an issue registered with the Securities and Exchange  Commission and was
part of a firm commitment underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  third  quarter  1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.





                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                      Transactions effected pursuant to Rule 10f-3

Transaction # 15: Emerging Opportunities Fund, purchase of Jacada Ltd.

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    Lehman Bros. Lehman Bros. was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

    S.G. Cowen was the affiliated underwriter of the Fund and the
    syndicate included various other underwriters.

3. Terms of the transaction.

Emerging Opportunities Fund, managed by Chartwell Investment Partners, purchased
10,640 Shares of Jacada Ltd., a company in continuous operation for 3+ years, in
an initial public  offering at the offering price of $11.00 per share on October
14, 1999. The underwriting  selling  concession was 4.00%. The percentage of the
offering  purchased by the Emerging  Opportunities Fund was 0.2364% of the total
offering.  The  security  purchased  was  part of an issue  registered  with the
Securities  and  Exchange   Commission  and  was  part  of  a  firm   commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made. .

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  fourth  quarter 1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.








                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                    Transactions effected pursuant to Rule 10f-3

Transaction # 16: Emerging Opportunities Fund, purchase of Charter
Communications, Inc.

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    Allen & Co. Allen & Co. was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

    S.G. Cowen and Salomon Smith Barney were the affiliated underwriters of the
    Fund and the syndicate included various other underwriters.

3. Terms of the transaction.

Emerging Opportunities Fund, managed by Chartwell Investment Partners, purchased
3,000 Shares of Charter Communications,  Inc., a company in continuous operation
for 3+ years,  in an initial public offering at the offering price of $16.00 per
share on November 8, 1999. The  underwriting  selling  concession was 2.75%. The
percentage  of the offering  purchased by the  Emerging  Opportunities  Fund was
0.0018%  of the total  offering.  The  security  purchased  was part of an issue
registered  with the Securities  and Exchange  Commission and was part of a firm
commitment underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made. .

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  fourth  quarter 1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                      Transactions effected pursuant to Rule 10f-3

Transaction # 17: Emerging Opportunities Fund, purchase of Netzee Inc.

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    Suntrust Equitable. Suntrust Equitable was not an affiliated
    underwriter of the Fund.

2. Identify the underwriting syndicate's members.

    Robinson-Humphrey  was  the  affiliated  underwriter  of the  Fund  and  the
    syndicate included various other underwriters.

3. Terms of the transaction.

Emerging Opportunities Fund, managed by Chartwell Investment Partners, purchased
1,000 Shares of Netzee Inc., a company in continuous  operation for 3+ years, in
an initial public offering at the offering price of $14.00 per share on November
9, 1999. The  underwriting  selling  concession was 3.93%. The percentage of the
offering  purchased by the Emerging  Opportunities Fund was 0.0227% of the total
offering.  The  security  purchased  was  part of an issue  registered  with the
Securities  and  Exchange   Commission  and  was  part  of  a  firm   commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made. .

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  fourth  quarter 1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                     Transactions effected pursuant to Rule 10f-3

Transaction # 18: Emerging Opportunities Fund,purchase of Rainmaker Systems,Inc.

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

 Donaldson, Lufkin & Jenrette. Donaldson, Lufkin & Jenrette was not an
 affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

    S.G. Cowen was the affiliated underwriter of the Fund and the syndicate
    included various other underwriters.

3. Terms of the transaction.

Emerging Opportunities Fund, managed by Chartwell Investment Partners, purchased
8,350 Shares of Rainmaker Systems,  Inc., a company in continuous  operation for
3+ years, in an initial public offering at the offering price of $8.00 per share
on November  17,  1999.  The  underwriting  selling  concession  was 4.25%.  The
percentage  of the offering  purchased by the  Emerging  Opportunities  Fund was
0.1670%  of the total  offering.  The  security  purchased  was part of an issue
registered  with the Securities  and Exchange  Commission and was part of a firm
commitment underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made. .

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  fourth  quarter 1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                    Transactions effected pursuant to Rule 10f-3

Transaction # 19: Emerging Opportunities Fund, purchase of  NDS Group Plc - ADR

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    Morgan Stanley.Morgan Stanley was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   S.G. Cowen was the affiliated underwriter of the Fund and the syndicate
   included various other underwriters.

3. Terms of the transaction.

Emerging Opportunities Fund, managed by Chartwell Investment Partners, purchased
4,180 Shares of NDS Group Plc - ADR, a company in  continuous  operation  for 3+
years,  in an initial public  offering at the offering price of $20.00 per share
on November  22,  1999.  The  underwriting  selling  concession  was 3.60%.  The
percentage  of the offering  purchased by the  Emerging  Opportunities  Fund was
0.0464%  of the total  offering.  The  security  purchased  was part of an issue
registered  with the Securities  and Exchange  Commission and was part of a firm
commitment underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made. .

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  fourth  quarter 1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.






                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                  Transactions effected pursuant to Rule 10f-3

Transaction # 20: Emerging Opportunities Fund, purchase of Tritel Inc.

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    Goldman Sachs. Goldman Sachs was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Robinson-Humphrey  was  the  affiliated  underwriter  of  the  Fund  and  the
   syndicate included various other underwriters.

3. Terms of the transaction.

Emerging Opportunities Fund, managed by Chartwell Investment Partners, purchased
8,400 Shares of Tritel Inc., a company in continuous  operation for 3+ years, in
an initial public offering at the offering price of $18.00 per share on December
13, 1999. The underwriting  selling  concession was 4.17%. The percentage of the
offering  purchased by the Emerging  Opportunities Fund was 0.0896% of the total
offering.  The  security  purchased  was  part of an issue  registered  with the
Securities  and  Exchange   Commission  and  was  part  of  a  firm   commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made. .

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  fourth  quarter 1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                           Transactions effected pursuant to Rule 10f-3

Transaction # 21: Long-Term Bond Fund, purchase of Voicestream Wireless Holdings
- - 144A, 10.375%, due 11/15/09.

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    Donaldson, Lufkin & Jenrette. Donaldson, Lufkin & Jenrette was not an
    affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Long-Term Bond Fund,  managed by Western Asset  Management,  purchased  $130,000
principal  face of  Voicestream  Wireless  Holdings,  a  company  in  continuous
operation for 3+ years,  in an initial public  offering at the offering price of
$100.00 per unit on November 4, 1999.  The  underwriting  spread paid was 1.50%.
The percentage of the offering  purchased by the Long-Term Bond Fund was 0.0118%
of the total offering.  The security  purchased was part of an issue  registered
with the  Securities and Exchange  Commission and was part of a firm  commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  fourth  quarter 1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                           Transactions effected pursuant to Rule 10f-3

Transaction # 22: Long-Term Bond Fund, purchase of Voicestream Wireless Holdings
(Discount) - 144A, 11.875%, due 11/15/09.

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

    Donaldson, Lufkin & Jenrette. Donaldson, Lufkin & Jenrette was not an
    affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Long-Term  Bond Fund,  managed by Western Asset  Management,  purchased  $80,000
principal  face of  Voicestream  Wireless  Holdings,  a  company  in  continuous
operation for 3+ years,  in an initial public  offering at the offering price of
$56.010 per unit on November 4, 1999.  The  underwriting  spread paid was 2.60%.
The percentage of the offering  purchased by the Long-Term Bond Fund was 0.0111%
of the total offering.  The security  purchased was part of an issue  registered
with the  Securities and Exchange  Commission and was part of a firm  commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  fourth  quarter 1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.





                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                           Transactions effected pursuant to Rule 10f-3

Transaction # 23: Long-Term Bond Fund, purchase of Republic of Columbia,  9.75%,
due 04/23/09.

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

   Morgan Stanley. Morgan Stanley was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Long-Term Bond Fund,  managed by Western Asset  Management,  purchased  $780,000
principal face of Republic of Columbia, a country in continuous operation for 3+
years,  in an initial public  offering at the offering price of $92.773 per unit
on November 17, 1999. The underwriting spread paid was 0.750%. The percentage of
the  offering  purchased  by the  Long-Term  Bond Fund was  0.1560% of the total
offering.  The  security  purchased  was  part of an issue  registered  with the
Securities  and  Exchange   Commission  and  was  part  of  a  firm   commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  fourth  quarter 1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.








                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                           Transactions effected pursuant to Rule 10f-3

Transaction # 24: Long-Term Bond Fund, purchase of Lockheed Martin,  8.500%, due
12/01/29.

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

   Goldman Sachs. Goldman Sachs was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Long-Term Bond Fund,  managed by Western Asset  Management,  purchased  $670,000
principal  face of Lockheed  Martin,  a company in  continuous  operation for 3+
years,  in an initial public  offering at the offering price of $99.609 per unit
on November 23, 1999. The underwriting spread paid was 0.875%. The percentage of
the  offering  purchased  by the  Long-Term  Bond Fund was  0.0536% of the total
offering.  The  security  purchased  was  part of an issue  registered  with the
Securities  and  Exchange   Commission  and  was  part  of  a  firm   commitment
underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  fourth  quarter 1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.









                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O

                           Transactions effected pursuant to Rule 10f-3

Transaction # 25: Intermediate-Term Bond Fund, purchase of Ford Motor Credit,
7.375%, due 10/28/09

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

   Morgan Stanley. Morgan Stanley was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Intermediate-Term   Bond   Fund,   managed   by   Travelers   Asset   Management
International,  purchased  $4,800,000  principal  face of Ford Motor  Credit,  a
company in continuous  operation for 3+ years,  in an initial public offering at
the  offering  price of $99.812 per unit on October 21, 1999.  The  underwriting
spread  paid  was  0.425%.  The  percentage  of the  offering  purchased  by the
Intermediate-Term  Bond Fund was  0.9600% of the total  offering.  The  security
purchased  was part of an issue  registered  with the  Securities  and  Exchange
Commission and was part of a firm commitment underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  fourth  quarter 1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                           Transactions effected pursuant to Rule 10f-3

Transaction # 26: Global High Yield Bond Fund, purchase of PTC International
Finance II 11.25%, due 12/01/09

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

     Merrill Lynch. Merrill Lynch was not an affiliated underwriter of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Global  High  Yield  Bond  Fund,  managed  by Credit  Suisse  Asset  Management,
purchased  $135,000  principal face of PTC International  Finance,  a company in
continuous operation for 3+ years, in an initial public offering at the offering
price of $98.530 per unit on November 16, 1999. The underwriting spread paid was
2.75%.  The  percentage of the offering  purchased by the Global High Yield Bond
Fund was 0.0900% of the total  offering.  The security  purchased was part of an
issue  registered with the Securities and Exchange  Commission and was part of a
firm commitment underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  fourth  quarter 1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.







                          American Odyssey Funds, Inc.
                          Form: N-SAR December 31, 1999
                              Attachment - Item 77O


                           Transactions effected pursuant to Rule 10f-3

Transaction # 27: Global High Yield Bond Fund, purchase of Nuevo Grupo
Iusacell S.A. - 144A, 11.25%, due 12/01/06

If any  such  transactions  were  effected  during  the  reporting  period,  the
following information should be furnished:

1. From whom were the securities acquired.

   Chase Securities. Chase Securities was not an affiliated underwriter
   of the Fund.

2. Identify the underwriting syndicate's members.

   Salomon  Smith  Barney  was the  affiliated  underwriter  of the Fund and the
   syndicate included various other underwriters.

3. Terms of the transaction.

Global  High  Yield  Bond  Fund,  managed  by Credit  Suisse  Asset  Management,
purchased  $320,000  principal  face of Nuevo Grupo  Iusacell  S.A, a company in
continuous operation for 3+ years, in an initial public offering at the offering
price of $100.00 per unit on December 9, 1999. The underwriting  spread paid was
2.875%.  The percentage of the offering  purchased by the Global High Yield Bond
Fund was 0.0914% of the total  offering.  The security  purchased was part of an
issue  registered with the Securities and Exchange  Commission and was part of a
firm commitment underwriting.

4. Information or materials upon which the determination  described in paragraph
(h)(3) of the rule 10f-3 was made.

The information described in item 1 through 3 above was provided to the Board of
Directors  at its  regularly  scheduled  fourth  quarter 1999 meeting as well as
information  supporting the  reasonableness  of the selling  concession  paid to
certify  that the purchase was made in  compliance  with the Board  adopted rule
10f-3 procedures.



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