EDGAR  EXHIBIT  12

Exhibit  12


The  RISA  Fund
[DATE],  2001


                             DRAFT


                               _____________, 2001


The  RISA  Fund
225  South  15th  Street,  Suite  930
Philadelphia,  PA  19102


Re:     Acquisition  of  Assets  of  The  RISA  Fund


Ladies  and  Gentlemen:

     You  have  asked  for  our  opinion  as  to  certain  Federal  income  tax
consequences  of  the  transaction  described  below.

                           Parties to the Transaction

     The  RISA  Fund  ("Target  Fund")  is a series of Harvest Funds, a Delaware
business  trust.

     Calvert  South Africa Fund ("Acquiring Fund") is a series of Calvert Impact
Fund,  Inc.,  a  Maryland  corporation.

                       Description of Proposed Transaction

     In  the  proposed  transaction  (the "Reorganization"), Acquiring Fund will
acquire  all  of  the  assets of Target Fund in exchange for shares of Acquiring
Fund  of  equivalent  value  and the assumption of the identified liabilities of
Target  Fund. Target Fund will then dissolve and distribute all of the Acquiring
Fund  shares  which it holds to its shareholders pro rata in proportion to their
shareholdings  in  Target Fund, in complete redemption of all outstanding shares
of  Target  Fund.

                         Scope of Review and Assumptions

     In  rendering  our  opinion,  we  have reviewed and relied upon the form of
Agreement and Plan of Reorganization between Acquiring Fund and Target Fund (the
"Reorganization  Agreement")  which is enclosed in a prospectus/proxy statement,
registration  number 33-44968, to be filed with the United States Securities and
Exchange  Commission  on  or  about April 17, 2000, which describes the proposed
transactions,  and  on  the  information  provided  in  such  prospectus/proxy
statement.  We  have  relied, without independent verification, upon the factual
statements  made  therein,  and  assume that there will be no change in material
facts  disclosed  therein  between  the  date of this letter and the date of the
closing  of  the  transaction.  We  further  assume that the transaction will be
carried  out  in  accordance  with  the  Reorganization  Agreement.

                                 Representations

     Written  representations,  copies  of  which are attached hereto, have been
made to us by the appropriate officers of Target Fund and Acquiring Fund, and we
have  without  independent  verification  relied  upon  such  representations in
rendering  our  opinions.

                                    Opinions

     Based  on  and  subject  to the foregoing, and our examination of the legal
authority  we  have  deemed  to  be  relevant,  we  have the following opinions:

     1.     The  transfer  of  all  of the assets of Target Fund in exchange for
shares  of  Acquiring  Fund  and  assumption by Acquiring Fund of the identified
specified  liabilities  of  Target  Fund  followed  by  the distribution of said
Acquiring  Fund  shares  to  the  shareholders of Target Fund in dissolution and
liquidation  of  Target Fund will constitute a reorganization within the meaning
of   368(a)(1)(C) of the Internal Revenue Code of 1986, as amended (the "Code"),
and  Acquiring  Fund  and Target Fund will each be "a party to a reorganization"
within  the  meaning  of   368(b)  of  the  Code.

     2.     No  gain  or  loss  will  be  recognized  by Acquiring Fund upon the
receipt  of  the  assets  of  Target  Fund solely in exchange for Acquiring Fund
shares  and  the  assumption  by Acquiring Fund of the identified liabilities of
Target  Fund.

     3.     No  gain or loss will be recognized to Target Fund upon the transfer
of  its  assets  to Acquiring Fund in exchange for Acquiring Fund shares and the
assumption  by  Acquiring  Fund of the identified liabilities of Target Fund, or
upon  the  distribution  (whether actual or constructive) of such Acquiring Fund
shares  to  the  shareholders  of  Target Fund in exchange for their Target Fund
shares.

     4.     The  shareholders of Target Fund will recognize no gain or loss upon
the  exchange  of  their  Target  Fund  shares  for  Acquiring  Fund  shares  in
liquidation  of  Target  Fund.

     5.     The  aggregate  basis  of the Acquiring Fund shares received by each
Target  Fund  shareholder pursuant to the Reorganization will be the same as the
aggregate  basis  of the Target Fund shares held by such shareholder immediately
prior  to  the  Reorganization.

     6.     The  holding  period  of  the Acquiring Fund shares received by each
Target  Fund  shareholder  will  include the period during which the Target Fund
shares  exchanged  therefor  were  held by such shareholder, provided the Target
Fund  shares  were  held  as  a capital asset on the date of the Reorganization.

     7.     The  basis  of  the assets of Target Fund acquired by Acquiring Fund
will  be  the  same  as  the  basis  of those assets in the hands of Target Fund
immediately prior to the Reorganization, and the holding period of the assets of
Target  Fund in the hands of Acquiring Fund will include the period during which
those  assets  were  held  by  Target  Fund.

     This opinion letter is delivered to you in satisfaction of the requirements
of  Section  8(d)  of  the  Reorganization  Agreement.  We hereby consent to the
filing  of this opinion as an exhibit to the Registration Statement on Form N-14
relating  to  the Reorganization and to use of our name and any reference to our
firm  in  such  Registration  Statement  or  in  the  prospectus/proxy statement
constituting  a  part  thereof.  In giving such consent, we do not thereby admit
that  we  come  within  the  category of persons whose consent is required under
Section  7  of  the  Securities  Act  of  1933,  as  amended,  or  the rules and
regulations  of  the  Securities  and  Exchange  Commission  thereunder.

                                   Very  truly  yours,



                                   SULLIVAN  &  WORCESTER  LLP