EX-99.p.2


                              DELAWARE INVESTMENTS


                                 CODE OF ETHICS


CREDO

It is the duty of all Delaware Investments employees,  officers and directors to
conduct  themselves with  integrity,  and at all times to place the interests of
Fund  shareholders and account holders first. In the interest of this credo, all
personal Securities  transactions will be conducted  consistent with the Code of
Ethics  and in such a manner as to avoid any  actual or  potential  conflict  of
interest or any abuse of an individual's  position of trust and  responsibility.
The  fundamental  standard  of this Code is that  personnel  should not take any
inappropriate advantage of their positions.

It is unlawful for certain persons,  including any employee, officer or director
of any Fund, investment adviser or principal underwriter, in connection with the
purchase or sale by such  person of a Security  held or to be acquired by a Fund
or an account:

(1)  To employ any device, scheme or artifice to defraud a Fund or an account;

(2)  To make any untrue  statement of a material fact to a Fund or an account or
     omit to state a material  fact  necessary  in order to make the  statements
     made to a Fund or an account,  in light of the  circumstances in which they
     are made, not misleading;

(3)  To engage in any act, practice or course of business that operates or would
     operate as a fraud or deceit on a Fund or an account; or

(4)  To  engage  in any  manipulative  practice  with  respect  to a Fund  or an
     account.

Rule 17j-1 of the  Investment  Company Act of 1940 also  requires that each Fund
(listed  on  Appendix  A),  Delaware  Investments'  Adviser,   sub-adviser,  and
principal  underwriter  adopt a  written  code of ethics  containing  provisions
reasonably  necessary  to  prevent  certain  persons  from  engaging  in acts in
violation of the above standard and shall use reasonable diligence and institute
procedures reasonably necessary to prevent violations of the Code.

This  Code of Ethics  is being  adopted  by the  following  Delaware  Investment
companies (collectively  "Delaware") in compliance with the requirements of Rule
17j-1 of the  Investment  Company Act of 1940 and Rule 204A-1 of the  Investment
Advisers Act of 1940,  to effect the purpose of the Credo set forth above and to
comply with the recommendations of the Investment Company  Institute's  Advisory
Group on Personal Investing:


                                       1


     DELAWARE MANAGEMENT BUSINESS TRUST
     DELAWARE CAPITAL MANAGEMENT
     DELAWARE MANAGEMENT COMPANY
     DELAWARE INVESTMENT ADVISERS
     DELAWARE LINCOLN CASH MANAGEMENT
     DELAWARE ASSET ADVISERS
     DELAWARE DISTRIBUTORS, L.P.
     RETIREMENT FINANCIAL SERVICES, INC.
     DELAWARE SERVICE COMPANY, INC.
     DELAWARE MANAGEMENT TRUST COMPANY

DEFINITIONS:

"Access  Person"  means (i) a  supervised  person  who has  access to  nonpublic
information  regarding clients' Securities  transactions,  is involved in making
Securities  recommendations to clients,  who has access to such  recommendations
that are  nonpublic,  or who has access to nonpublic  information  regarding the
portfolio  holdings of  affiliated  Funds (see  Appendix A); (ii) any  director,
officer,  general partner or Advisory Person of a Fund or of a Fund's investment
adviser; or (iii) any director, officer or general partner of a Fund's principal
underwriter who, in the ordinary course of business,  makes,  participates in or
obtains information regarding,  the purchase or sale of Securities by a Fund, or
whose  functions  or duties in the  ordinary  course of  business  relate to the
making of any  recommendation  to a Fund  regarding  the purchase or sale of its
Securities.  Those  persons  deemed  Access  Persons  will be  notified  of this
designation.

"Advisory Person" means (i) any director,  officer,  general partner or employee
of a Fund or investment adviser (or of any company in a control  relationship to
the Fund or an investment  adviser)  who, in connection  with his or her regular
functions or duties makes, participates in, or obtains information regarding the
purchase  or sale of  Securities  by a Fund,  or whose  functions  relate to the
making of any  recommendations  with respect to such purchase or sales,  or (ii)
any natural person in a control  relationship to a Fund or an investment adviser
who obtains information concerning  recommendations made to the Fund with regard
to the  purchase  or  sale  of  Securities  by a  Fund.  For  purposes  of  this
definition,  "control"  has the same meaning as set forth in Section  2(a)(9) of
the Investment Company Act of 1940.

"Affiliated  Person"  means any  officer,  director,  partner,  or employee of a
Delaware Fund or any subsidiary of Delaware  Management  Holdings,  Inc. and any
other person so designated by the Compliance Department.

"Beneficial  ownership"  shall be as defined  in  Section  16 of the  Securities
Exchange  Act of 1934  and  the  rules  and  regulations  thereunder.  Generally
speaking,   a  person  who,  directly  or  indirectly,   through  any  contract,
arrangement, understanding, relationship or otherwise, has or shares a direct or
indirect  pecuniary  interest  in a  Security,  is a  "beneficial  owner" of the
Security.  For example, a person is normally regarded as the beneficial owner of
Securities  held by  members of his or her  immediate  family  sharing  the same
household.  Additionally,  ownership of derivative  Securities  such as options,
warrants  or  convertible  Securities  which  confer  the right to


                                       2


acquire  the  underlying  Security  at  a  fixed  price  constitutes  Beneficial
Ownership of the underlying Security itself.

"Control"  shall mean  investment  discretion  in whole or in part of an account
regardless  of Beneficial  Ownership,  such as an account for which a person has
power of attorney or authority to effect transactions.

"De Minimis Purchases or Sales" shall mean purchases or sales by covered persons
of up to 500 shares of stock in a company that is in the Standard and Poor's 500
Index provided that Delaware has not traded more than 10,000 shares of that same
stock  during the last two  trading  days and there are no open  orders for that
stock on the Trading Desk.

"Director" shall mean any person who serves as a director or trustee of any Fund
(listed on Appendix A) that is advised by Delaware.

"High Quality  Short-Term Debt Instruments" shall mean any instrument that has a
maturity  at  issuance of less that 366 days and that is rated in one of the two
highest  rating  categories  by  a  Nationally  Recognized   Statistical  Rating
Organization.

"Investment  Personnel"  means any employee of a Fund, an investment  adviser or
affiliated  company,  other than a Portfolio  Manager  who, in  connection  with
his/her  regular  functions or duties,  makes, or participates in the making of,
investment decisions affecting an investment company, and any control person who
obtains information  concerning the recommendation of Securities for purchase or
sale by a Fund or an account.  Investment  Personnel  also include the staff who
support a Portfolio Manager including analysts,  administrative assistants, etc.
Investment Personnel by definition are Access Persons.

"Managed  Accounts"  means an account that is  professionally  managed through a
wrap program.  Managed  Accounts  require  pre-approval  through the  Compliance
Department  prior to starting up the account.  The  Compliance  Department  will
consider the facts and circumstances of the account, including the functions and
duties of the employees,  when approving or denying such accounts.  In addition,
preclearance is exempt with Managed Accounts,  however, all trades still require
reporting and duplicate  statements and confirmations are required to be sent to
the Compliance  Department.  Preclearance is only exempt for trades initiated by
the wrap manager. All trades initiated by the employee require preclearance.

"Portfolio  Manager"  means any person who, in connection  with his/her  regular
functions  or  duties,  makes or  participates  in,  the  making  of  investment
decisions effecting an investment company. Portfolio Manager includes all equity
analysts and fixed income  research  analysts and traders  (excluding  municipal
bond,  money market and private  placement).  Analysts or traders from  excluded
teams  may  be  included  under  the  definition  of  Portfolio  Manager  at the
discretion of the Chief Compliance Officer. Portfolio Managers by definition are
Access Persons.

"Security"  shall  have the  meaning  as set forth in  Section  2(a)(36)  of the
Investment  Company Act of 1940,  except  that it shall not  include  Securities
issued or guaranteed by the government of the United States or by any , bankers'
acceptances,  bank  certificates  of deposit,  commercial  paper,  High


                                       3


Quality Short-Term Debt Instruments including repurchase  agreements,  shares of
open-end registered  investment companies (other than non-money market Funds for
which Delaware Investments is the adviser and sub-adviser,  see Appendix A for a
list of these  Funds),  and  municipal  fund  Securities  (i.e.  529 Plans).  In
addition,  the  purchase,  sale  or  exercise  of a  derivative  Security  shall
constitute the purchase or sale of the  underlying  Security.  Federal  agencies
(e.g., Fannie Mae and Freddie Mae) instruments are subject to the Code of Ethics
preclearance  and reporting  requirements.  Preclearance  of all Corporate Bonds
shall be done on an issuer basis instead of on a mere cusip basis.  However, the
purchase  or sale of the debt  instrument  of an issuer  which does not give the
holder the right to  purchase  the  issuer's  stock at a fixed  price,  does not
constitute a purchase or sale of the issuer's stock.  Security being "considered
for purchase or sale" or "being  purchased or sold" means when a  recommendation
to purchase or sell the Security or an option to purchase or sell a Security has
been made and  communicated  to the Trading  Desk and with respect to the person
making the recommendation,  when such person seriously considers making, or when
such person  knows or should know that another  person is seriously  considering
making, such a recommendation.

Security  "held or to be acquired" by an account  means (i) any Security  which,
within  the most  recent  fifteen  days  (a) is or has been  held by the Fund or
account;  or (b) is  being,  or  has  been,  considered  by the  account  or its
investment  adviser for purchase by the Fund or account;  and (ii) any option to
purchase  or sell,  and any  Security  convertible  into or  exchangeable  for a
Security.

PROHIBITED ACTIVITIES

I.   The following restrictions apply to all Affiliated Persons, Access Persons,
     Investment Personnel and Portfolio Managers.

(a) No  Affiliated  Person,  Access  Person,  Investment  Personnel or Portfolio
Manager  shall  engage in any act,  practice or course of  conduct,  which would
violate the  provisions of Rule 17j-1 set forth above,  or any other  applicable
federal securities laws.

(b) No  Affiliated  Person,  Access  Person,  Investment  Personnel or Portfolio
Manager shall purchase or sell,  directly or  indirectly,  any Security which to
his/her knowledge is being actively considered for purchase or sale by Delaware;
except that this prohibition shall not apply to:

     (A)  purchases  or sales that are  nonvolitional  on the part of either the
     Person or the Account;
     (B) purchases which are part of an automatic dividend reinvestment plan;
     (C) purchases  effected upon the exercise of rights issued by an issuer pro
     rata to all holders of a class of its Securities, to the extent such rights
     were acquired from such issuer, and sales of such rights so acquired;
     (D) other  purchases  and sales  specifically  approved by the President or
     Chief Executive Officer,  with the advice of the General Counsel and/or the
     Compliance   Director,   and  deemed  appropriate  because  of  unusual  or
     unforeseen circumstances.  A list of Securities excepted will be maintained
     by the Compliance Department.
     (E) purchases or sales made by a wrap manager in an Affiliated  Person's or
     Access Person's Managed  Account,  provided that such purchases or sales do
     not reflect a pattern of conflict.


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(c) Except for trades  that meet the  definition  of de minimis,  no  Affiliated
Person,  Access Person,  Investment Personnel or Portfolio Manager may execute a
buy or sell order for an account in which he or she has Beneficial  Ownership or
Control until the third trading day following the execution of a Delaware buy or
sell order in that same  Security.  All trades  that meet the  definition  of de
minimus,  however,  must first be  precleared  by the  Compliance  Department in
accordance with Section I(g) below.

(d) No  Affiliated  Person or Access  Person  may  purchase  an  initial  public
offering (IPO) without first receiving preclearance.

(e) No  Affiliated  Person,  Access  Person,  Investment  Personnel or Portfolio
Manager may purchase any private placement without express PRIOR written consent
by the Compliance Department.  This prior approval will take into account, among
other factors,  whether the investment opportunity should be reserved for a Fund
or an account and whether the opportunity is being offered to a person by virtue
of his or her position with Delaware. All private placement holdings are subject
to  disclosure to the  Compliance  Department.  Any  Affiliated  Person,  Access
Person, Investment Personnel or Portfolio Manager that holds a private placement
must receive  permission from the Compliance or Legal  Departments  prior to any
participation by such person in Delaware's consideration of an investment in the
same issuer. In such  circumstances,  Delaware's decision to purchase securities
of the issuer will be subject to an independent  review by Investment  Personnel
with no personal interest in the issuer.

(f) Despite any fault or  impropriety,  any  Affiliated  Person,  Access Person,
Investment  Personnel  or  Portfolio  Manager who  executes a buy or sell for an
account in which he/she has  Beneficial  Ownership or Control  either (i) before
the third trading day  following  the execution of a Delaware  order in the same
Security,  or (ii) when there are pending  orders for a Delaware  transaction as
reflected  on the open order  blotter,  shall  forfeit any profits  made (in the
event of purchases) or loss avoided (in the event of sales), whether realized or
unrealized,  in the period from the date of the personal  transaction to the end
of the proscribed trading period.  Payment of the amount forfeited shall be made
by check or in cash to a charity of the person's  choice and a copy of the check
or receipt must be forwarded to the Compliance Department.

(g) Except for Managed Accounts meeting the provisions of Section I(b)(E) above,
each  Affiliated  Person or Access  Person's  personal  transactions,  including
transactions that may be considered de minimus,  must be precleared by using the
Personal Transaction System. The information must be submitted prior to entering
any orders for personal transactions. Preclearance is only valid for the day the
request  is  submitted.  If  the  order  is  not  executed  the  same  day,  the
preclearance  request  must be  resubmitted.  Regardless  of  preclearance,  all
transactions  remain  subject to the  provisions of (f) above.  PRECLEARANCE  OF
FIXED INCOME  SECURITIES  MUST BE RECEIVED  DIRECTLY FROM A COMPLIANCE  OFFICER.
(Systematic preclearance is not available for fixed income securities.)

(h) All Mutual Funds that are now subject to the Code of Ethics will be required
to be held for a minimum of 60 days before selling the Fund at a profit. Closing
positions at a loss is not prohibited.


                                       5


II.  In  addition  to  the  requirements  noted  in  Section  I,  the  following
     additional  restrictions  apply to all  Investment  Personnel and Portfolio
     Managers.

(a)  All  Investment  Personnel  and  Portfolio  Managers  are  prohibited  from
purchasing any initial public offering (IPO).

(b)  Short  term  trading  resulting  in a profit  is  prohibited.  All  opening
positions  must be held for a period of 60 days, in the  aggregate,  before they
can be closed at a profit.  Any short term  trading  profits  are subject to the
disgorgement  procedures  outlined  above  and at the  maximum  level of  profit
obtained.  The closing of positions at a loss is not  prohibited.  Stock Options
are also included in the 60 day holding period.

(c)  All  Investment  Personnel  and  Portfolio  Managers  are  prohibited  from
receiving  anything  of more than a de  minimis  value from any person or entity
that does business  with or on behalf of any account or client.  Things of value
may  include,  but  not  be  limited  to,  travel  expenses,  special  deals  or
incentives.

(d) All  Investment  Personnel  and  Portfolio  Managers  require  PRIOR written
approval  from the Legal or Compliance  Department  before they may serve on the
board of directors of any public company.

III. In addition to the  requirements  noted in Sections I and II, the following
     additional restrictions apply to all Portfolio Managers.

(a) No  Portfolio  Manager  may  execute a buy or sell order for an account  for
which he/she has Beneficial Ownership within seven calendar days before or after
an investment  company or separate  account that he/she  manages  trades in that
Security.

(b) Despite  any fault or  impropriety,  any  Portfolio  Manager who  executes a
personal  transaction  within seven  calendar days before or after an investment
company or separate  account that he/she manages trades in that Security,  shall
forfeit any profits  made (in the event of  purchases)  or loss  avoided (in the
event of sales), whether realized or unrealized,  in the period from the date of
the personal transaction to the end of the prescribed trading period. Payment of
the  amount  forfeited  shall be made by check  or in cash to a  charity  of the
person's  choice and a copy of the check or  receipt  must be  forwarded  to the
Compliance Department.


REQUIRED REPORTS

I.   The following  reports are required to be made by all  Affiliated  Persons,
     Access Persons, Investment Personnel, Portfolio Managers.

(a) Disclose  brokerage  relationships  at employment and at the time of opening
any new account.

(b) Direct their  brokers to supply to the  Compliance  Department,  on a timely
basis,  duplicate copies of all  confirmations and statements for all Securities
accounts and Managed Accounts. Where


                                       6


possible,  such confirmations and statements should be forwarded  electronically
to the Compliance Department. The Compliance Department, from time to time, will
compare such confirmations and statements against precleared transactions in the
Personal Transaction System to monitor compliance with the Code.

(c) All Delaware  Investments  Mutual Funds and Optimum Fund Trust accounts will
be required to be held in-house.

(d) Each quarter,  no later than 20 days after the end of the calendar  quarter,
submit to the Compliance  Department a personal  transaction summary showing all
transactions  in  Securities  in accounts  which such person has or acquires any
direct or indirect Beneficial  Ownership.  Any transactions effected pursuant to
an Automatic Investment Plan, however,  need not be reported.  Each Director who
is not an  interested  person  shall  submit  the  quarterly  reports  only  for
transactions  where at the time of the  transaction the Director knew, or in the
ordinary  course of  fulfilling  his official  duties as a Director  should have
known, that during the fifteen day period  immediately  before or after the date
of the  transaction  by the  Director,  such Security was purchased or sold by a
Fund or its investment adviser or was being considered for purchase or sale by a
Fund or its investment adviser.

Every report will contain the following information:

     (i) the date of the  transaction,  the title and type of the Security,  the
     exchange  ticker symbol or CUSIP number,  if applicable,  the interest rate
     and  maturity  date,  if  applicable,  and the  number  of  shares  and the
     principal amount of each Security involved;
     (ii) the nature of the transaction (i.e., purchase,  sale or any other type
     of acquisition or disposition);
     (iii) the price at which the transaction was effected;
     (iv) the name of the broker, dealer or bank effecting the transaction;
     (v) for any account established by such person in which any Securities were
     held during the quarter for the direct or indirect  benefit of such person,
     the  name  of the  broker,  dealer  or  bank  with  whom  the  account  was
     established and the date the account was established; and
     (vi) the date that the report is submitted to the Compliance Department.

(e) All Affiliated Persons,  Access Persons,  Investment Personnel and Portfolio
Managers must,  initially upon receipt of this Code, upon receipt of any and all
amendments to this Code, and annually,  certify that they have  received,  read,
understand  and  complied  with  this  Code of  Ethics  and all  disclosure  and
reporting requirements contained therein.

II.  In  addition  to the above  reporting  requirements,  all  Access  Persons,
     Investment  Personnel and Portfolio  Managers (other than Directors who are
     not Interested Persons) must:

(a)  Provide an initial holdings report no later than 10 days upon  commencement
     of employment that discloses  information regarding all personal Securities
     holdings,  including (i) the title,  type,  exchange ticker symbol or CUSIP
     number,  if  applicable,  the number of shares and the principal  amount of
     each Security;  (ii) the name of any broker,  dealer or bank with whom such
     person  maintains  an  account  in which any  Securities  were held for the
     direct  or  indirect  benefit  of  such


                                       7


     person as of the date of the commencement of employment, and (iii) the date
     that the report was  submitted to the  Compliance  Department.  This report
     must be current as of a date no more than 45 days  before the  commencement
     of employment.

(b)  Provide an annual  holdings  report  containing  information  regarding all
     personal  Securities  holdings,  including  (i) the title,  type,  exchange
     ticker symbol or CUSIP number, if applicable,  the number of shares and the
     principal amount of each Security;  (ii) the name of any broker,  dealer or
     bank with whom such  person  maintains  an account in which any  Securities
     were held for the direct or indirect benefit of such person,  and (iii) the
     date that the report  was  submitted  to the  Compliance  Department.  This
     report  must be current as of a date no more than 45 days before the report
     is submitted and must be submitted at least annually.

SANCTIONS/VIOLATIONS

Strict  compliance with the provisions of the Code of Ethics is considered to be
a basic provision of your employment.  Any violation of the Code of Ethics by an
employee will be considered serious and may result in disciplinary action, which
may include, but is not limited to unwinding of trades, disgorgement of profits,
warning,  monetary fine or censure,  suspension of personal trading  privileges,
and suspension or termination  of employment.  Repeated  offenses will likely be
subject to additional sanctions of increasing severity.


ADMINISTRATIVE PROCEDURES

(a) The Compliance  Department of Delaware will identify all Affiliated Persons,
Access Persons, Investment Personnel and Portfolio Managers and will notify them
of this  classification  and their  obligations  under this Code. The Compliance
Department  will ensure that all such  persons  initially  receive a copy of the
Code of Ethics and any and all  subsequent  amendments  thereto.  The Compliance
Department   will  also  maintain   procedures   regarding  the  review  of  all
notifications  and reports  required to be made pursuant to Rule 17j-1 under the
Investment Company Act of 1940, Rule 204A-1 under the Investment Advisers Act of
1940, or this Code and the Compliance  Department will review all  notifications
and reports, such as portfolio holdings and Securities transaction reports.

(b) All Affiliated Persons,  Access Persons,  Investment Personnel and Portfolio
Managers shall report any apparent  violations of the  prohibitions or reporting
requirements  contained  in  this  Code  of  Ethics  promptly  to the  Legal  or
Compliance Department.  The Legal or Compliance Department shall report any such
apparent  violations to the Chief Compliance  Officer and the President or Chief
Executive  Officer.  Such Chief  Executive  Officer or President,  or both, will
review the reports made and determine whether or not the Code of Ethics has been
violated  and shall  determine  what  sanctions,  if any,  should be  imposed in
addition to any that may already  have been  imposed.  On a quarterly  basis,  a
summary report of material violations of the Code and the sanctions imposed will
be made to the Board of Directors  or  Committee  of Directors  created for that
purpose.  In  reviewing  this  report,  the  Board  will  consider  whether  the
appropriate  sanctions  were  imposed.  When the Legal  Department  finds that a
transaction  otherwise  reportable  above could not  reasonably be found


                                       8


to have  resulted in a fraud,  deceit or  manipulative  practice in violation of
Rule 17j-1(b),  it may, in its  discretion,  lodge a written  memorandum of such
finding in lieu of reporting the transaction.

(c) All material purchases and sales  specifically  approved by the President or
Chief  Executive  Officer in  accordance  with Section  (I)(b)(D) of  Prohibited
Activities,  as  described  herein,  shall be  reported to the Board at its next
regular meeting.

(d) The Board of Directors,  including a majority of independent Directors, must
approve  the  Fund's  Code,  as well as the Code of any  adviser  and  principal
underwriter.  If an adviser or underwriter makes a material changes to its Code,
the Board must approve the material  change within six months after the adoption
of such  change.  The Board must base its  approval  of a Code of  ethics,  or a
material  change  to a  Code,  upon  a  determination  that  the  Code  contains
provisions  reasonably  necessary to prevent  "Access Persons from violating the
anti-fraud provisions of the Rule 17j-1.

(e) At least once a year,  the Board must be provided a written report from each
Rule 17j-1  organization  that  describes  issues that arose during the previous
year under the Code or  procedures  applicable  to the Rule 17j-1  organization,
including,  but not limited  to, a summary of the  existing  procedures  and any
changes  during the past year,  information  about  material  Code or  procedure
violations and sanctions imposed in response to those material  violations,  and
any recommended changes to the Code based on past experience,  evolving industry
practice  or  developments  in  applicable  laws or  regulations.  In  addition,
annually and before the Board approves a material  change to the Code, the Board
must be provided with a written  report from each Rule 17j-1  organization  that
certifies  to the  Fund's  Board that the Rule 17j-1  organization  has  adopted
procedures reasonably necessary to prevent its Access Persons from violating its
Code of Ethics.

RECORDKEEPING

Please see Procedures  Regarding Books and Records To be Kept and Maintained for
Code of Ethics recordkeeping requirements.


                                       9


Appendix A - List of Mutual Funds/Collective  Investment Vehicles subject to the
Code of Ethics

o    All Delaware Investments Family of Funds
o    All Optimum Fund Trust Funds
o    AssetMark Tax-Exempt Fixed Income Fund
o    Consulting Group Capital Markets Funds - Large Capitalization Growth Equity
     Investments
o    Consulting Group Capital Markets Funds - Small  Capitalization Value Equity
     Investments o First Mercantile Trust Preferred Trust Fund
o    Lincoln Variable Insurance Product Trusts - LVIP Delaware Bond Fund
o    Lincoln Variable  Insurance  Product Trusts - LVIP Delaware Growth & Income
     Fund
o    Lincoln Variable Insurance Product Trusts - LVIP Delaware Managed Fund
o    Lincoln Variable Insurance Product Trusts - LVIP Money Market Fund
o    Lincoln Variable  Insurance Product Trusts - LVIP Delaware Social Awareness
     Fund
o    Lincoln  Variable   Insurance   Product  Trusts  -  LVIP  Delaware  Special
     Opportunities Fund
o    MassMutual Select Funds - MassMutual Select Aggressive Growth Fund
o    MassMutual Select Funds - MassMutual Select Emerging Growth Fund
o    MML Series Investment Fund - MML Emerging Growth Fund
o    PNC Capital Opportunities Fund
o    MetLife Investments Funds - MetLife Investment Small Company Stock Fund
o    MLIG Roszel/Delaware Small Cap Portfolio
o    MLIG Roszel/Delaware Trend Portfolio
o    Northern Equity Funds - Multi-Manager Large Cap Fund
o    Russell Investment Company - Select Growth Fund
o    Russell Investment Company - Fixed Income I/Russell Multi-Manager Bond Fund
o    Russell Investment Company - Fixed Income III Fund
o    Russell Investment Company - Multistrategy Bond Fund
o    Russell Investment Company - Tax-Exempt Bond Fund
o    Russell Trust Company - Russell Common Trust Core Bond Fund
o    Russell Trust Company - Russell Concentrated Aggressive Portfolio Fund
o    Russell Trust Company - Russell Growth Fund
o    Russell Trust Company - Russell International Fund
o    Russell Trust Company - Russell Long Duration Fixed Income Fund
o    Russell Company Limited - Russell Multi-Strategy Global Bond Fund
o    Russell Investments (Cayman) Limited - Russell Investment Company plc - The
     U.S. Bond Fund
o    Russell Company Limited - Integritas  Mutli-Manager  Fund plc - U.S. Equity
     Fund
o    SEI Global Investments Fund plc - US Large Cap Growth Fund
o    SEI Global Markets Fund plc - US Small Companies Fund
o    SEI Institutional Investments Trust - Large Cap Fund
o    SEI Institutional Investments Trust - Large Cap Diversified Alpha Fund
o    SEI Institutional Investments Trust - Small Cap Fund
o    SEI Institutional Investments Trust - Small/Mid Cap Equity Fund
o    SEI Institutional Managed Trust - Large Cap Diversified Alpha Fund


                                       10


o    SEI Institutional Managed Trust - Large Cap Growth Fund
o    SEI Institutional Managed Trust - Small Cap Growth Fund
o    SEI Institutional Managed Trust - Tax Managed Large Cap Fund
o    SEI Institutional Managed Trust - Tax Managed Small Cap Fund
o    SEI Investments Group of Funds - U.S. Large Company Equity Fund
o    SEI Tax-Exempt Trust - Institutional Tax-Free Fund
o    Wilshire Mutual Funds, Inc. - Large Company Growth Portfolio


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