COMMERCE FUNDS
NSAR-A, EX-99.77D, 2000-06-28
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Sub-Item 77D:  POLICIES WITH RESPECT TO SECURITY INVESTMENTS

The  investment  policies of the  Short-Term  Government  Fund (the "Fund") were
amended to permit  investments  in  asset-backed  securities  and corporate debt
obligations.  The Fund may invest up to 35% of the Fund's  investments in either
of these securities.

The text of the  proposal  to  change  the  investment  policies  of the Fund as
described above is hereby provided:

RESOLVED,  that the  proposal to amend the  investment  policies of the
Short-Term Government Fund to permit the Short-Term Government Fund to invest in
asset-backed  securities  and corporate debt  obligations  be, and it hereby is,
approved.


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