0000923705-97-000005 Sample Contracts

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WITNESSETH:
Transfer Agency Agreement • June 27th, 1997 • Invesco Specialty Funds Inc • Colorado
MOYE, GILES, O'KEEFE, VERMEIRE & GORRELL A Law Partnership Including Professional Corporations 29th Floor 1225 Seventeenth Street Denver, Colorado 80202-5529 Telephone (303) 292-2900 Telecopier (303) 292-4510 May 18, 1994
Invesco Specialty Funds Inc • June 27th, 1997

This is in response to your request for our opinion as to the legality of the registration of an indefinite number of shares of capital stock ($0.01) par value per share) of INVESCO Specialty Funds, Inc., being registered with the Securities and Exchange Commission under the Investment Company Act of 1940 and the Securities Act of 1933, as amended (Form N-1A). This share registration is being requested pursuant to the provisions of Rule 24f-2 under Section 24(f) of the Investment Company Act of 1940.

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