SECTION 16(a) BENEFICIAL OWNERSHIP REPORTING
COMPLIANCE

Section 16(a) of the Exchange Act and Section 30(h) of
the 1940 Act, as applied to the Fund, requires the
Fund's officers and trustees, certain officers and
directors of the investment advisers, affiliates of the
investment advisers and persons who own more than
ten percent of a registered class of the Fund's equity
securities, to file reports of ownership and changes in
ownership with the Commission and the NYSE.

Based solely upon the Fund's review of the copies of
such forms filed on EDGAR or written representations
from the trustees and officers of the Fund and the
filings by the beneficial holders of greater than 10% of a
Fund's shares, to the knowledge of the Fund, for the
fiscal year ended October 31, 2010, the filings required
by the Exchange Act were made on a timely basis,
except that: (i) one Form 4 filing was submitted late on
behalf of Ms. Nancy Maasbach, a Trustee of the Fund,
related to a purchase of Fund shares, and (ii) Craig
MacDonald and Archie Struthers each filed a late Form
3 filing following their respective appointments as
directors of the fund's investment adviser.