Exhibit 99.77Q3 CERT To Form N-SAR




Registrant Name: PROGRESSIVE RETURN FUND, INC

File Number: 811-5891

Registrant CIK Number: 0000854580




(a)(i) The President and Treasurer have concluded that the
Progressive Return Fund, Inc. disclosure controls and procedures
(as defined in rule 30a-2(c) under the Investment Company Act)
provide reasonable assurances that material information relating
to Progressive Return Fund, Inc. is made known to them by the
appropriate persons, based on their evaluation of these controls
and procedures as of a date within 90 days of the filing date of
this report.


(a)(ii) There were no significant changes in Progressive Return
Fund, Inc. internal controls or in other factors that could
Significantly affect these controls subsequent to the date
of the evaluation referenced in (a)(i) above.


(a)(iii) Certifications:



I, Ralph W. Bradshaw, certify that:

1. I have reviewed this report on Form N-SAR of Progressive
Return Fund, Inc.;

2. Based on my knowledge, this report does not contain any
untrue statement of a material fact or omit to state a material
fact necessary to make the statements made, in light of the
circumstances under which such statements were made, not
misleading with respect to the period covered by this report;


3. Based on my knowledge, the financial information included
in this report, and the financial statements on which the
financial information is based, fairly present in all material
respects the financial condition, results of operations,
changes in net assets, and cash flows (if the financial statements
are required to include a statement of cash flows) of the
registrant as of, and for, the periods presented in this report;


4. The registrant's other certifying officers and I are responsible
for establishing and maintaining disclosure controls and procedures
as defined in rule 30a-2(c) under the Investment Company Act) for
the registrant and have:

a)designed such disclosure controls and procedures to ensure that
material information relating to the registrant, including its
consolidated subsidiaries, is made known to us by others within
those entities, particularly during the period in which this
report is being prepared;

b) evaluated the effectiveness of the registrant's disclosure
controls and procedures as of a date within 90 days prior to the
filing date of this report (the "Evaluation Date"); and

c) presented in this report our conclusions about the effectiveness
of the disclosure controls and procedures based on our evaluation
as of the Evaluation Date;

5. The registrant's other certifying officers and I have disclosed,
based on our most recent evaluation, to the registrant's auditors
and the audit committee of the registrant's board of directors
(or persons performing the equivalent functions):

a) all significant deficiencies in the design or operation of
internal controls which could adversely affect the registrant's
ability to record, process, summarize, and report financial data
and have identified for the registrant's auditors any material
weaknesses in internal controls; and

b) any fraud, whether or not material, that involves management
or other employees who have a significant role in the registrant's
internal controls; and

6. The registrant's other certifying officers and I have indicated
in this report whether or not there were significant changes in
internal controls or in other factors that could significantly
affect internal controls subsequent to the date of our most recent
evaluation, including any corrective actions with regard to
significant deficiencies and material weaknesses.

/s/Ralph W. Bradshaw
Ralph W. Bradshaw

President

Date: February 27, 2003


I, Gary A. Bentz, certify that:

1. I have reviewed this report on Form N-SAR of Progressive
Return Fund, Inc.;

2. Based on my knowledge, this report does not contain any untrue
statement of a material fact or omit to state a material fact
necessary to make the statements made, in light of the circumstances
under which such statements were made, not misleading with respect
to the period covered by this report;

3. Based on my knowledge, the financial information included in
this report, and the financial statements on which the financial
information is based, fairly present in all material respects
the financial condition, results of operations, changes in net
assets, and cash flows (if the financial statements are required
to include a statement of cash flows) of the registrant as of,
and for, the periods presented in this report;

4. The registrant's other certifying officers and I are responsible
for establishing and maintaining disclosure controls and procedures
(as defined in rule 30a-2(c) under the Investment Company Act) for
the registrant and have:


a)designed such disclosure controls and procedures to ensure that
material information relating to the registrant, including its
consolidated subsidiaries, is made known to us by others within
those entities, particularly during the period in which this report
is being prepared;


b) evaluated the effectiveness of the registrant's disclosure
controls and procedures as of a date within 90 days prior to
the filing date of this report (the "Evaluation Date"); and


c) presented in this report our conclusions about the effectiveness
 of the disclosure controls and procedures based on our evaluation
 as of the Evaluation Date;


5. The registrant's other certifying officers and I have disclosed,
 based on our most recent evaluation, to the registrant's auditors
 and the audit committee of the registrant's board of directors
 (or persons performing the equivalent functions):


a) all significant deficiencies in the design or operation of
 internal controls which could adversely affect the registrant's
 ability to record, process, summarize, and report financial data
 and have identified for the registrant's auditors any material
 weaknesses in internal controls; and


b) any fraud, whether or not material, that involves management
 or other employees who have a significant role in the registrant's
 internal controls; and


6. The registrant's other certifying officers and I have indicated
 in this report whether or not there were significant changes in
 internal controls or in other factors that could significantly
 affect internal controls subsequent to the date of our most recent
 evaluation, including any corrective actions with regard to
 significant deficiencies and material weaknesses.


/s/Gary A. Bentz

Gary A. Bentz


Treasurer

Date: February 27, 2003