Previously published particle-γ coincidence data on the 64 Ni(p, p γ) 64 Ni and 64 Ni(d, pγ) 65 Ni reactions were further analyzed to study the statistical properties of γ decay in 64,65 Ni. To do so, the γ decay to the quasicontinuum region and discrete low-lying states was investigated at γ-ray energies of 2.0-9.6 and 1.6-6.1 MeV in 64 Ni and 65 Ni, respectively. In particular, the dependence of the γ-strength function with initial and final excitation energy was studied to test the validity of the generalized Brink-Axel hypothesis. Finally, the role of fluctuations in transition strengths was estimated as a function of γ-ray and excitation energy. The γ-strength function is consistent with the hypothesis of the independence of initial excitation energy, in accordance with the generalized Brink-Axel hypothesis. The results show that the γ decay to low-lying levels displays large fluctuations for low initial excitation energies.