In the Matter of Philam Strategic Growth Fund, Inc.

March 11, 2019

CORPORATE GOVERNANCE AND FINANCE DEPARTMENT

IN THE MATTER OF PHILAM STRATEGIC GROWTH FUND, INC., registrant.

AMENDED REGISTRATION STATEMENT

NOTICE

Notice is hereby given that on December 18, 2018 an Amended Registration Statement was filed with the Securities and Exchange Commission on behalf of Philam Strategic Growth Fund, Inc. ("PSGF") to reflect the following changes in its registration statement as follows:

Subject

Original Provision

Proposed Amendments

Investment Objectives

PSGF is an aggressive type of investment dealing with equity securities. An adequate portion of the portfolio will be invested in cash or near cash assets to ensure that redemptions will adequately and immediately served.

To achieve long-term capital growth.

Portfolio Mix

PSGF will invest in a combination of stocks with large and medium capitalization that can provide good value and capital appreciation over the medium term. Management, earnings potential, strong balance sheet and attractive valuations will be the primary criteria for stock selections. Changes in the macroeconomic conditions can dictate the equities that the Fund will invest in. Temporary shifts to cash or fixed-income instruments may be done as a defensive move. The minimum investment amount...

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