<DOCUMENT>
<TYPE>EX-99
<SEQUENCE>6
<FILENAME>ex77q3a.txt
<DESCRIPTION>EVALUATION OF DISCLOSURE CONTROLS AND PROCEDURES
<TEXT>
Exhibit 77Q3:A

As of November 27, 2002, an evaluation was performed under the
supervision and with the participation of the officers of
Bancroft Convertible Fund, Inc. (the "Company"), including the
principal executive officer ("PEO") and principal financial
officer ("PFO"), of the effectiveness of the Company's
disclosure controls and procedures.  Based on that evaluation,
the Company's officers, including the PEO and PFO, concluded
that, as of November 27, 2002, the Company's disclosure controls
and procedures were reasonably designed so as to ensure that
material information relating to the Company is made known
to the PEO and PFO.  There have been no significant changes in
the Company's internal controls or in other factors that could
significantly affect these controls subsequent to the date of
their evaluation and until the filing of this report, including
any corrective actions with regard to significant deficiencies
and material weaknesses.


</TEXT>
</DOCUMENT>
