SPECTRA FUND INC
NSAR-A/A, 1999-06-30
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                                  SPECTRA FUND
                                  EXHIBIT 77D
                                   FORM N-SAR
                                 APRIL 30, 1999


                                  SPECTRA FUND
                                  EXHIBIT 77 D
                                   FORM N-SAR
                                 APRIL 30, 1999


Effective December 8, 1998, Spectra Fund changed its status from a non-
diversified to a diversified investment company.




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