SPECTRA FUND INC
NSAR-B/A, EX-99.77I, 2000-12-29
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77 I. (B) TERMS OF NEW OR AMENDED SECURITIES:


     Spectra Fund
     ------------

     The creation of a new class of shares, Class A shares, was approved at a
     Special Meeting of the Board of Trustees held on February 14, 2000. The
     Class A shares bear a front-end sales charge. A Rule 18f-3 Plan was
     approved to reflect the new dual-class structure. Class A shares were duly
     established and became effective on June 30, 2000.




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