EX-99.77O RULE 10F-3 2 hyffpe.htm RULE 10F-3 Unassociated Document
 
 

 
Managed High Yield Plus Fund Inc.


For period ending
May 31, 2015
   
Exhibit 77O
File number
811-8765
     
FORM 10f-3
 
Rule 144A Securities
 
 
FUND: Managed High Yield Plus Fund, Inc.
 
 
Name of Adviser or Sub-Adviser:  UBS Global Asset Management (Americas) Inc.
 
 
1.  Issuer:  Dynegy Finance I/II Inc. 6.75% due 11/01/2019
 
2.  Date of Purchase:  10/10/2014                                                                3.  Date offering commenced: 10/10/2014
 
 
4.  Underwriter(s) from whom purchased:   Morgan Stanley
 
 
5.  “Affiliated Underwriter" managing or participating in syndicate:
 
 
UBS Investment Bank
 
 
6.  Aggregate principal amount or number of shares purchased:  $4,000,000 firmwide
 
 
7.  Aggregate principal amount or total number of shares of offering:  $2,100,000,000
 
 
8.  Purchase price per unit or share (net of fees and expenses):$100.00
 
 
9.  Initial public offering price:  $100.00
 
 
10.  Commission, spread or profit:  _1.0_______%              $____________
 
11.  Have the following conditions been satisfied?
YES
NO
a.The securities are sold in an offering exempt from registration under Section 4(2) of the Securities Act of 1933, Rule 144A or Regulation D.
b.The securities are sold to persons reasonably believed to be “qualified institutional buyers” (“QIBs”).
c.The securities are reasonably believed to be eligible for resale to other QIBs.
d.The securities were purchased prior to the end of the first day on which any sales are made (or, if a rights offering, the securities were purchased on or before the fourth day preceding the day on which the offering terminated).
 
 
X_____
 
 
X______
 
X______
 
 
 
 
 
X______
 
 
 
_______
 
 
_______
 
_______
 
 
 
 
 
_______
 
e.The securities were purchased at a price not more than the price paid by each other purchaser in the offering or any concurrent offering.
f.The underwriting was a firm commitment underwriting.
YES
 
X______
 
X______
NO
 
_______
 
_______
g.The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period.
 
 
X______
 
 
_______
h.The issuer of the securities and any predecessor has been in continuous operation for not less than three years.
 
 
X______
 
 
_______
i.The amount of such securities purchased by the Fund and all other accounts over which the Adviser (or Sub-Adviser, if applicable) exercises investment discretion did not exceed 25% of the principal amount of the offering.
 
 
 
 
X______
 
 
 
 
_______
j.No Affiliated Underwriter benefited directly or indirectly from the purchase.
 
X______
 
 
_______
Note: Refer to the Rule 10f-3 Procedures for the definitions of the capitalized terms above.  In particular, “Affiliated Underwriter” is defined as affiliates of the Adviser or Sub-Adviser participating in a selling syndicate, as applicable.
 
Approved:   /s/ John Hwang                                                                                           Date:10/24/2014___
 
Print Name:   John Hwang
 


 
 

 
Managed High Yield Plus Fund Inc.



FORM 10f-3
 
Rule 144A Securities
 
 
FUND: Managed High Yield Plus Fund, Inc.
 
 
Name of Adviser or Sub-Adviser:  UBS Global Asset Management (Americas) Inc.
 
 
1.  Issuer:  Dynegy Finance I/II Inc. 7.375% due 11/01/2022
 
2.  Date of Purchase:  10/10/2014                                                                3.  Date offering commenced: 10/10/2014
 
 
4.  Underwriter(s) from whom purchased:   Morgan Stanley
 
 
5.  “Affiliated Underwriter" managing or participating in syndicate:
 
 
UBS Investment Bank
 
 
6.  Aggregate principal amount or number of shares purchased: $2,000,000 firmwide
 
 
7.  Aggregate principal amount or total number of shares of offering:  $
 
 
8.  Purchase price per unit or share (net of fees and expenses):$100.00
 
 
9.  Initial public offering price:  $100.00
 
 
10.  Commission, spread or profit:  _1.0________%              $____________
 
11.  Have the following conditions been satisfied?
YES
NO
a.The securities are sold in an offering exempt from registration under Section 4(2) of the Securities Act of 1933, Rule 144A or Regulation D.
b.The securities are sold to persons reasonably believed to be “qualified institutional buyers” (“QIBs”).
c.The securities are reasonably believed to be eligible for resale to other QIBs.
d.The securities were purchased prior to the end of the first day on which any sales are made (or, if a rights offering, the securities were purchased on or before the fourth day preceding the day on which the offering terminated).
 
 
X_____
 
 
X______
 
X______
 
 
 
 
 
X______
 
 
 
_______
 
 
_______
 
_______
 
 
 
 
 
_______
 
e.The securities were purchased at a price not more than the price paid by each other purchaser in the offering or any concurrent offering.
f.The underwriting was a firm commitment underwriting.
YES
 
X______
 
X______
NO
 
_______
 
_______
g.The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period.
 
 
X______
 
 
_______
h.The issuer of the securities and any predecessor has been in continuous operation for not less than three years.
 
 
X______
 
 
_______
i.The amount of such securities purchased by the Fund and all other accounts over which the Adviser (or Sub-Adviser, if applicable) exercises investment discretion did not exceed 25% of the principal amount of the offering.
 
 
 
 
X______
 
 
 
 
_______
j.No Affiliated Underwriter benefited directly or indirectly from the purchase.
 
X______
 
 
_______
Note: Refer to the Rule 10f-3 Procedures for the definitions of the capitalized terms above.  In particular, “Affiliated Underwriter” is defined as affiliates of the Adviser or Sub-Adviser participating in a selling syndicate, as applicable.
 
Approved:   /s/ John Hwang                                                           ____________                                 Date:10/24/2014___
 
Print Name:   John Hwang
 

 
 

 
Managed High Yield Plus Fund Inc.



FORM 10f-3
 
Rule 144A Securities
 
 
FUND: Managed High Yield Plus Fund, Inc.
 
 
Name of Adviser or Sub-Adviser:  UBS Global Asset Management (Americas) Inc.
 
 
1.  Issuer:  Targa Resources Partners 4.125% due 11/15/2019
 
2.  Date of Purchase:  10/23/2014                                                                3.  Date offering commenced: 10/23/2014
 
 
4.  Underwriter(s) from whom purchased:   Bank of America
 
 
5.  “Affiliated Underwriter" managing or participating in syndicate:
 
 
UBS Investment Bank
 
 
6.  Aggregate principal amount or number of shares purchased: $9,000,000 firmwide
 
 
7.  Aggregate principal amount or total number of shares of offering:  $800,000,000
 
 
8.  Purchase price per unit or share (net of fees and expenses):$100.00
 
 
9.  Initial public offering price:  $100.00
 
 
10.  Commission, spread or profit:  _1.0________%              $____________
 
11.  Have the following conditions been satisfied?
YES
NO
a.The securities are sold in an offering exempt from registration under Section 4(2) of the Securities Act of 1933, Rule 144A or Regulation D.
b.The securities are sold to persons reasonably believed to be “qualified institutional buyers” (“QIBs”).
c.The securities are reasonably believed to be eligible for resale to other QIBs.
d.The securities were purchased prior to the end of the first day on which any sales are made (or, if a rights offering, the securities were purchased on or before the fourth day preceding the day on which the offering terminated).
 
 
X_____
 
 
X______
 
X______
 
 
 
 
 
X______
 
 
 
_______
 
 
_______
 
_______
 
 
 
 
 
_______
 
e.The securities were purchased at a price not more than the price paid by each other purchaser in the offering or any concurrent offering.
f.The underwriting was a firm commitment underwriting.
YES
 
X______
 
X______
NO
 
_______
 
_______
g.The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period.
 
 
X______
 
 
_______
h.The issuer of the securities and any predecessor has been in continuous operation for not less than three years.
 
 
X______
 
 
_______
i.The amount of such securities purchased by the Fund and all other accounts over which the Adviser (or Sub-Adviser, if applicable) exercises investment discretion did not exceed 25% of the principal amount of the offering.
 
 
 
 
X______
 
 
 
 
_______
j.No Affiliated Underwriter benefited directly or indirectly from the purchase.
 
X______
 
 
_______
Note: Refer to the Rule 10f-3 Procedures for the definitions of the capitalized terms above.  In particular, “Affiliated Underwriter” is defined as affiliates of the Adviser or Sub-Adviser participating in a selling syndicate, as applicable.
 
Approved:   /s/ John Hwang                                                           ____________                                 Date:10/24/2014___
 
Print Name:   John Hwang
 


 
 

 
Managed High Yield Plus Fund Inc.



FORM 10f-3
 
Rule 144A Securities
 
 
FUND: Managed High Yield Plus Fund, Inc.
 
 
Name of Adviser or Sub-Adviser:  UBS Global Asset Management (Americas) Inc.
 
 
1.  Issuer:  HD Supply Inc. 5.25% due 12/15/2021
 
2.  Date of Purchase:  11/19/2014                                                                3.  Date offering commenced: 11/19/2014
 
 
4.  Underwriter(s) from whom purchased:   Bank of America
 
 
5.  “Affiliated Underwriter" managing or participating in syndicate:
 
 
UBS Investment Bank
 
 
6.  Aggregate principal amount or number of shares purchased: $6,000,000 firmwide
 
 
7.  Aggregate principal amount or total number of shares of offering:  $1,250,000,000
 
 
8.  Purchase price per unit or share (net of fees and expenses):$100.00
 
 
9.  Initial public offering price:  $100.00
 
 
10.  Commission, spread or profit:  _1.25_____%              $____________
 
11.  Have the following conditions been satisfied?
YES
NO
a.The securities are sold in an offering exempt from registration under Section 4(2) of the Securities Act of 1933, Rule 144A or Regulation D.
b.The securities are sold to persons reasonably believed to be “qualified institutional buyers” (“QIBs”).
c.The securities are reasonably believed to be eligible for resale to other QIBs.
d.The securities were purchased prior to the end of the first day on which any sales are made (or, if a rights offering, the securities were purchased on or before the fourth day preceding the day on which the offering terminated).
 
 
X_____
 
 
X______
 
X______
 
 
 
 
 
X______
 
 
 
_______
 
 
_______
 
_______
 
 
 
 
 
_______
 
e.The securities were purchased at a price not more than the price paid by each other purchaser in the offering or any concurrent offering.
f.The underwriting was a firm commitment underwriting.
YES
 
X______
 
X______
NO
 
_______
 
_______
g.The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period.
 
 
X______
 
 
_______
h.The issuer of the securities and any predecessor has been in continuous operation for not less than three years.
 
 
X______
 
 
_______
i.The amount of such securities purchased by the Fund and all other accounts over which the Adviser (or Sub-Adviser, if applicable) exercises investment discretion did not exceed 25% of the principal amount of the offering.
 
 
 
 
X______
 
 
 
 
_______
j.No Affiliated Underwriter benefited directly or indirectly from the purchase.
 
X______
 
 
_______
Note: Refer to the Rule 10f-3 Procedures for the definitions of the capitalized terms above.  In particular, “Affiliated Underwriter” is defined as affiliates of the Adviser or Sub-Adviser participating in a selling syndicate, as applicable.
 
Approved:   /s/ John Hwang                                                           ____________                                 Date:11/21/2014___
 
Print Name:   John Hwang
 


 
 

 
Managed High Yield Plus Fund Inc.



FORM 10f-3
 
Registered Domestic Securities and Government Securities
 
 
FUND: Managed High Yield Plus Fund, Inc.
 
 
Name of Adviser or Sub-Adviser:  UBS Global Asset Management (Americas) Inc.
 
 
1.  Issuer:  MarkWest Energy Partners L.P. 4.875% due 12/01/2024
 
2.  Date of Purchase:  11/18/2014                                                                3.  Date offering commenced: 11/18/2014
 
 
4.  Underwriter(s) from whom purchased:   Wells Fargo Securities
 
 
5.  “Affiliated Underwriter" managing or participating in syndicate:
 
 
UBS Investment Bank
 
 
6.  Aggregate principal amount or number of shares purchased: $7,000,000 firmwide
 
 
7.  Aggregate principal amount or total number of shares of offering:  $500,000,000
 
 
8.  Purchase price per unit or share (net of fees and expenses):$100.00
 
 
9.  Initial public offering price:  $100.00
 
 
10.  Commission, spread or profit:  _1.0______%              $____________
 
11.  Have the following conditions been satisfied?
YES
NO
a.The securities are part of an issue registered under the Securities Act of 1933 that is being offered to the public, or is part of an issue of government securities (as defined in section 2(a)(16) of the 1940 Act).
b.The securities were purchased prior to the end of the first day on which any sales are made (or, if a rights offering, the securities were purchased on or before the fourth day preceding the day on which the offering terminated).
c.The securities purchased at a price not more than the price paid by each other purchaser in the offering.
d.The underwriting was a firm commitment underwriting.
 
 
 
X_____
 
 
 
 
X______
 
 
X______
 
X______
 
 
 
 
_______
 
 
 
 
_______
 
 
_______
 
_______
 
e.The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period.
 
 
X______
 
 
_______
f.The issuer of the securities and any predecessor has been in continuous operation for not less than three years.
 
 
X______
 
 
_______
g.The amount of such securities purchased by the Fund and all other accounts over which the Adviser (or Sub-Adviser, if applicable) exercises investment discretion did not exceed 25% of the principal amount of the offering.
 
 
 
 
X_______
 
 
 
 
_______
h.No Affiliated Underwriter benefited directly or indirectly from the purchase.
 
X_______
 
 
_______
Note: Refer to the Rule 10f-3 Procedures for the definitions of the capitalized terms above.  In particular, “Affiliated Underwriter” is defined as affiliates of the Adviser or Sub-Adviser participating in a selling syndicate, as applicable.
 
Approved:   /s/ John Hwang                                                                                                Date: 11/21/2014__
 
Print Name:   John Hwang
 


 
 

 
Managed High Yield Plus Fund Inc.



FORM 10f-3
 
Registered Domestic Securities and Government Securities
 
 
FUND: Managed High Yield Plus Fund, Inc.
 
 
Name of Adviser or Sub-Adviser:  UBS Global Asset Management (Americas) Inc.
 
 
1.  Issuer:  MGM Resorts International 6% due 03/15/2023
 
2.  Date of Purchase:  11/20/2014                                                                3.  Date offering commenced: 11/20/2014
 
 
4.  Underwriter(s) from whom purchased:   Bank of America
 
 
5.  “Affiliated Underwriter" managing or participating in syndicate:
 
 
UBS Investment Bank
 
 
6.  Aggregate principal amount or number of shares purchased: $15,000,000 firmwide
 
 
7.  Aggregate principal amount or total number of shares of offering:  $1,150,000,000
 
 
8.  Purchase price per unit or share (net of fees and expenses):$100.00
 
 
9.  Initial public offering price:  $100.00
 
 
10.  Commission, spread or profit:  _1.0______%              $____________
 
11.  Have the following conditions been satisfied?
YES
NO
a.The securities are part of an issue registered under the Securities Act of 1933 that is being offered to the public, or is part of an issue of government securities (as defined in section 2(a)(16) of the 1940 Act).
b.The securities were purchased prior to the end of the first day on which any sales are made (or, if a rights offering, the securities were purchased on or before the fourth day preceding the day on which the offering terminated).
c.The securities purchased at a price not more than the price paid by each other purchaser in the offering.
d.The underwriting was a firm commitment underwriting.
 
 
 
X_____
 
 
 
 
X______
 
 
X______
 
X______
 
 
 
 
_______
 
 
 
 
_______
 
 
_______
 
_______
 

 
 

 
Managed High Yield Plus Fund Inc.



e.The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period.
 
 
X______
 
 
_______
f.The issuer of the securities and any predecessor has been in continuous operation for not less than three years.
 
 
X______
 
 
_______
g.The amount of such securities purchased by the Fund and all other accounts over which the Adviser (or Sub-Adviser, if applicable) exercises investment discretion did not exceed 25% of the principal amount of the offering.
 
 
 
 
X_______
 
 
 
 
_______
h.No Affiliated Underwriter benefited directly or indirectly from the purchase.
 
X_______
 
 
_______
Note: Refer to the Rule 10f-3 Procedures for the definitions of the capitalized terms above.  In particular, “Affiliated Underwriter” is defined as affiliates of the Adviser or Sub-Adviser participating in a selling syndicate, as applicable.
 
Approved:   /s/ John Hwang                                                                                                Date: 11/21/2014__
 
Print Name:   John Hwang
 


 
 

 
Managed High Yield Plus Fund Inc.




FORM 10f-3
 
Rule 144A Securities
 
 
FUND: Managed High Yield Plus Fund, Inc.
 
 
Name of Adviser or Sub-Adviser:  UBS Global Asset Management (Americas) Inc.
 
 
1.  Issuer:  UnityMedia Hessen/NRW 5% due 01/15/2025
 
2.  Date of Purchase:  12/03/2014                                                                3.  Date offering commenced: 12/03/2014
 
 
4.  Underwriter(s) from whom purchased:   Goldman Sachs
 
 
5.  “Affiliated Underwriter" managing or participating in syndicate:
 
 
UBS Investment Bank
 
 
6.  Aggregate principal amount or number of shares purchased: $15,000,000 firmwide
 
 
7.  Aggregate principal amount or total number of shares of offering:  $550,000,000
 
 
8.  Purchase price per unit or share (net of fees and expenses):$100,00
 
 
9.  Initial public offering price:  $100.00
 
 
10.  Commission, spread or profit:  _0.5________%              $____________
 
11.  Have the following conditions been satisfied?
YES
NO
a.The securities are sold in an offering exempt from registration under Section 4(2) of the Securities Act of 1933, Rule 144A or Regulation D.
b.The securities are sold to persons reasonably believed to be “qualified institutional buyers” (“QIBs”).
c.The securities are reasonably believed to be eligible for resale to other QIBs.
d.The securities were purchased prior to the end of the first day on which any sales are made (or, if a rights offering, the securities were purchased on or before the fourth day preceding the day on which the offering terminated).
 
 
X_____
 
 
X______
 
X______
 
 
 
 
 
X______
 
 
 
_______
 
 
_______
 
_______
 
 
 
 
 
_______
 
e.The securities were purchased at a price not more than the price paid by each other purchaser in the offering or any concurrent offering.
f.The underwriting was a firm commitment underwriting.
YES
 
X______
 
X______
NO
 
_______
 
_______
g.The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period.
 
 
X______
 
 
_______
h.The issuer of the securities and any predecessor has been in continuous operation for not less than three years.
 
 
X______
 
 
_______
i.The amount of such securities purchased by the Fund and all other accounts over which the Adviser (or Sub-Adviser, if applicable) exercises investment discretion did not exceed 25% of the principal amount of the offering.
 
 
 
 
X______
 
 
 
 
_______
j.No Affiliated Underwriter benefited directly or indirectly from the purchase.
 
X______
 
 
_______
Note: Refer to the Rule 10f-3 Procedures for the definitions of the capitalized terms above.  In particular, “Affiliated Underwriter” is defined as affiliates of the Adviser or Sub-Adviser participating in a selling syndicate, as applicable.
 
Approved:   /s/ John Hwang                                                           ____________                                 Date:12/22/2014___
 
Print Name:   John Hwang
 


 
 

 
Managed High Yield Plus Fund Inc.


FORM 10f-3
 
Registered Domestic Securities and Government Securities
 
 
FUND: Managed High Yield Plus Fund, Inc.
 
 
Name of Adviser or Sub-Adviser:  UBS Global Asset Management (Americas) Inc.
 
 
1.  Issuer:  HCA Inc. 5.375% due 02/01/2025
 
2.  Date of Purchase:  01/13/2015                                                                3.  Date offering commenced: 01/13/2015
 
 
4.  Underwriter(s) from whom purchased:   Wells Fargo Securities
 
 
5.  “Affiliated Underwriter" managing or participating in syndicate:
 
 
UBS Investment Bank
 
 
6.  Aggregate principal amount or number of shares purchased: $5,000,000 firmwide
 
 
7.  Aggregate principal amount or total number of shares of offering:  $1,000,000,000
 
 
8.  Purchase price per unit or share (net of fees and expenses):$100.00
 
 
9.  Initial public offering price:  $100.00
 
 
10.  Commission, spread or profit:  _1.0______%              $____________
 
11.  Have the following conditions been satisfied?
YES
NO
a.The securities are part of an issue registered under the Securities Act of 1933 that is being offered to the public, or is part of an issue of government securities (as defined in section 2(a)(16) of the 1940 Act).
b.The securities were purchased prior to the end of the first day on which any sales are made (or, if a rights offering, the securities were purchased on or before the fourth day preceding the day on which the offering terminated).
c.The securities purchased at a price not more than the price paid by each other purchaser in the offering.
d.The underwriting was a firm commitment underwriting.
 
 
 
X_____
 
 
 
 
X______
 
 
X______
 
X______
 
 
 
 
_______
 
 
 
 
_______
 
 
_______
 
_______
 

 
 

 
Managed High Yield Plus Fund Inc.



e.The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period.
 
 
X______
 
 
_______
f.The issuer of the securities and any predecessor has been in continuous operation for not less than three years.
 
 
X______
 
 
_______
g.The amount of such securities purchased by the Fund and all other accounts over which the Adviser (or Sub-Adviser, if applicable) exercises investment discretion did not exceed 25% of the principal amount of the offering.
 
 
 
 
X_______
 
 
 
 
_______
h.No Affiliated Underwriter benefited directly or indirectly from the purchase.
 
X_______
 
 
_______
Note: Refer to the Rule 10f-3 Procedures for the definitions of the capitalized terms above.  In particular, “Affiliated Underwriter” is defined as affiliates of the Adviser or Sub-Adviser participating in a selling syndicate, as applicable.
 
Approved:   /s/ John Hwang                                                                                                Date: 01/26/2015__
 
Print Name:   John Hwang
 

 
 

 
Managed High Yield Plus Fund Inc.





FORM 10f-3
 
Rule 144A Securities
 
 
FUND: Managed High Yield Plus Fund, Inc.
 
 
Name of Adviser or Sub-Adviser:  UBS Global Asset Management (Americas) Inc.
 
 
1.  Issuer:  Bombardier Inc. 5.5% due 09/15/2018
 
2.  Date of Purchase:  02/27/2015                                                                3.  Date offering commenced: 02/27/2015
 
 
4.  Underwriter(s) from whom purchased:   JP Morgan Securities
 
 
5.  “Affiliated Underwriter" managing or participating in syndicate:
 
 
UBS Investment Bank
 
 
6.  Aggregate principal amount or number of shares purchased: $5,000,000 firmwide
 
 
7.  Aggregate principal amount or total number of shares of offering:  $750,000,000
 
 
8.  Purchase price per unit or share (net of fees and expenses):$100.00
 
 
9.  Initial public offering price:  $100.00
 
 
10.  Commission, spread or profit:  _1.25________%              $____________
 
11.  Have the following conditions been satisfied?
YES
NO
a.The securities are sold in an offering exempt from registration under Section 4(2) of the Securities Act of 1933, Rule 144A or Regulation D.
b.The securities are sold to persons reasonably believed to be “qualified institutional buyers” (“QIBs”).
c.The securities are reasonably believed to be eligible for resale to other QIBs.
d.The securities were purchased prior to the end of the first day on which any sales are made (or, if a rights offering, the securities were purchased on or before the fourth day preceding the day on which the offering terminated).
 
 
X_____
 
 
X______
 
X______
 
 
 
 
 
X______
 
 
 
_______
 
 
_______
 
_______
 
 
 
 
 
_______
 
e.The securities were purchased at a price not more than the price paid by each other purchaser in the offering or any concurrent offering.
f.The underwriting was a firm commitment underwriting.
YES
 
X______
 
X______
NO
 
_______
 
_______
g.The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period.
 
 
X______
 
 
_______
h.The issuer of the securities and any predecessor has been in continuous operation for not less than three years.
 
 
X______
 
 
_______
i.The amount of such securities purchased by the Fund and all other accounts over which the Adviser (or Sub-Adviser, if applicable) exercises investment discretion did not exceed 25% of the principal amount of the offering.
 
 
 
 
X______
 
 
 
 
_______
j.No Affiliated Underwriter benefited directly or indirectly from the purchase.
 
X______
 
 
_______
Note: Refer to the Rule 10f-3 Procedures for the definitions of the capitalized terms above.  In particular, “Affiliated Underwriter” is defined as affiliates of the Adviser or Sub-Adviser participating in a selling syndicate, as applicable.
 
Approved:   /s/ John Hwang                                                           ____________                                 Date: 3/5/2015___
 
Print Name:   John Hwang