EXHIBIT 99.p1
[american century logo and text logo]

        American Century Investments
        WORKING WITH INTEGRITY...


CODE OF ETHICS
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Defined terms are in BOLD ITALICS. Frequently used terms are defined in Appendix
1.
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I.   PURPOSE OF CODE.

     The Code of Ethics was developed to guide the personal investment
     activities of American Century employees, officers and directors, including
     MEMBERS OF THEIR IMMEDIATE FAMILY. In doing so, it is intended to aid in
     the elimination and detection of personal securities transactions by
     American Century personnel that might be viewed as fraudulent or might
     conflict with the interests of our client portfolios. Primary among such
     transactions are the misuse for personal benefit of client trading
     information (so-called "front-running"), the misappropriation of investment
     opportunities that may be appropriate for investment by client portfolios,
     and excessive personal trading that may affect our ability to provide
     services to our clients.

     The Directors of American Century's registered investment companies (our
     "Fund Clients"(1)) who are not "interested persons" (the "Independent
     Directors") are covered under a separate Code applicable only to them.

     Violations of this Code must be promptly reported to the Chief Compliance
     Officer.

II.  WHY DO WE HAVE A CODE OF ETHICS?

     A.   INVESTORS HAVE PLACED THEIR TRUST IN AMERICAN CENTURY.

          As an investment adviser, American Century is entrusted with the
          assets of our clients for investment purposes. American Century's
          fiduciary responsibility to place the interests of our clients before
          our own and to avoid even the appearance of a conflict of interest
          extends to all American Century employees. Persons subject to this
          Code must adhere to this general principle as well as comply with the
          Code's specific provisions. This is how we earn and keep our clients'
          trust. To protect this trust, we will hold ourselves to the highest
          ethical standards.

     B.   AMERICAN CENTURY WANTS TO GIVE YOU FLEXIBLE INVESTING OPTIONS.

          Management believes that American Century's own mutual funds and other
          pooled investment vehicles provide a broad range of investment
          alternatives in virtually every segment of the securities market. We
          encourage American Century employees to use these vehicles for their
          personal investments. We do not encourage active trading by our
          employees. We recognize, however, that individual needs differ and
          that there are other attractive investment opportunities. As a result,
          this Code is intended to give you and your family flexibility to
          invest, without jeopardizing relationships with our clients.

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(1) See Schedule A for a listing of all of our Fund Clients.



AMERICAN CENTURY INVESTMENTS                                 CODE OF ETHICS
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          American Century employees are able to undertake personal transactions
          in stocks and other individual securities subject to the terms of this
          Code of Ethics. This Code of Ethics requires preclearance of all such
          transactions by Access, Investment, and Portfolio Persons, places
          further limitations on personal investments by Investment and
          Portfolio Persons, and requires transaction reporting by all
          employees.

     C.   FEDERAL LAW REQUIRES THAT WE HAVE A CODE OF ETHICS.

          The Investment Company Act of 1940 and the Investment Advisers Act of
          1940 require that we have safeguards in place to prevent personal
          investment activities that might take inappropriate advantage of our
          fiduciary position. These safeguards are embodied in this Code of
          Ethics.(2)

III. DOES THE CODE OF ETHICS APPLY TO YOU?

     YES! All American Century employees and contract personnel must observe the
     principles contained in the Code of Ethics. However, there are different
     requirements for different categories of employees. The category in which
     you have been placed generally depends on your job function, although
     unique circumstances may prompt us to place you in a different category.
     The range of categories is as follows:

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     FEWEST RESTRICTIONS------------------------------------> MOST RESTRICTIONS

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     NON-ACCESS            ACCESS              INVESTMENT             PORTFOLIO
      PERSON               PERSON                PERSON                PERSON
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     The standard profile for each of the categories is described below:

     A.   PORTFOLIO PERSONS.

          Portfolio Persons include portfolio managers (equity or fixed income)
          and any other Investment Persons (as defined below) with authority to
          enter purchase/sale orders on behalf of the funds.

     B.   INVESTMENT PERSONS.

          Investment Persons include

          *    Any SUPERVISED PERSONS that have access to nonpublic information
               regarding any client portfolio's securities trading, securities
               recommendations, or portfolio holdings or is involved in making
               securities recommendations that are nonpublic; and

          *    Any officers and directors of an INVESTMENT ADVISER.

          Such persons include but are not limited to investment analysts,
          equity traders, research and financial analyst personnel.

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(2)  Rule 17j-1 under the Investment Company Act of 1940 and Rule 204A-1 under
     the Investment Advisers Act of 1940 serve as a basis for much of what is
     contained in American Century's Code of Ethics.


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     C.   ACCESS PERSONS.

          Access Persons are persons who, in connection with their regular
          function and duties, consistently obtain information regarding current
          recommendations with respect to the purchase or sale of securities or
          real-time trading information concerning client portfolios. Examples
          include:

          *    Persons who are directly involved in the execution, clearance,
               and settlement of purchases and sales of securities (e.g. certain
               investment accounting personnel);

          *    Persons whose function requires them to evaluate trading activity
               on a real time basis (e.g. attorneys, accountants, portfolio
               compliance personnel);

          *    Persons who assist in the design, implementation, and maintenance
               of investment management technology systems (e.g. certain I/T
               personnel);

          *    Support staff and supervisors of the above if they are required
               to obtain such information as a part of their regular function
               and duties; and

          *    An officer or "interested" director of our Fund Clients.

          Single, infrequent, or inadvertent instances of access to current
          recommendations or real-time trading information or the opportunity to
          obtain such information through casual observance or bundled data
          security access is not sufficient to qualify you as an Access Person.

     D.   NON-ACCESS PERSONS.

          If you are an officer, director, employee or contractor of American
          Century and you do not fit into any of the above categories, you are a
          Non-Access Person. While your trading is not subject to preclearance
          and other restrictions applicable to Portfolio, Investment, and Access
          Persons, you are still subject to the remaining provisions of the Code
          and are required to report to American Century certain information
          regarding your brokerage accounts and accounts invested in REPORTABLE
          MUTUAL FUNDS.(3)

IV.  RESTRICTIONS ON PERSONAL INVESTING ACTIVITIES.

     A.   PRINCIPLES OF PERSONAL INVESTING.

          In keeping with applicable law and our high ethical standards,
          management of client portfolios should never be subordinated to
          personal gain or advantage. American Century employees, officers and
          directors may not misuse nonpublic information about client security
          holdings or portfolio transactions made or contemplated for a client
          for personal benefit or to cause others to benefit. Likewise, you may
          not cause a client portfolio to take action, or fail to take action,
          for personal benefit rather than the benefit of the client.

          In addition, investment opportunities appropriate for the funds should
          not be retained for personal benefit. Investment opportunities arising
          as a result of American Century

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(3) See Reporting Requirements for details on required reporting.

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          investment management activities must first be considered for
          inclusion in our client portfolios.

          In undertaking their personal securities transactions, all American
          Century employees, officers, and directors must comply with the
          FEDERAL SECURITIES LAWS and other governmental rules and regulations.

     B.   PRECLEARANCE OF PERSONAL SECURITIES TRANSACTIONS. [ACCESS, INVESTMENT,
          AND PORTFOLIO PERSONS]

          Preclearance of personal securities transactions allows American
          Century to prevent certain trades that may conflict with client
          trading activities. The nature of securities markets makes it
          impossible for us to perfectly predict those conflicts. As a
          consequence, even trades that are precleared can result in potential
          conflicts between your trades and those effected for clients. You are
          responsible for avoiding such conflicts with any client portfolios for
          which you make investment recommendations. You have an obligation to
          American Century and its clients to avoid even a perception of a
          conflict of interest with respect to personal trading activities.

          All Portfolio, Investment, and Access Persons must comply with the
          following preclearance procedures prior to entering into (i) the
          purchase or sale of a SECURITY for your own account or (ii) the
          purchase or sale of a SECURITY for an account for which you are a
          BENEFICIAL OWNER(4):

          1.   Is the SECURITY a "Code-Exempt Security"?

               Check Appendix 3 to see if the SECURITY is listed as a
               CODE-EXEMPT SECURITY. If it is, then you may execute the
               transaction. Otherwise, proceed to the next step.

          2.   Preclear the transaction with the Legal Department's Compliance
               Group.(5)

               There are two ways to do this:

               a.   Use the "PTRA" routine in the CICS system and enter your
                    request at the Personal Trade System screen.

               b.   If you do not have access to "PTRA," e-mail your request to
                    "LG-PERSONAL SECURITY TRADES" (or
                    "LG-PERSONAL_SECURITY_TRADES@AMERICANCENTURY.COM," if
                    sending from outside American Century's Lotus Notes system),
                    and provide the following information:

                    *    Issuer name;

                    *    Ticker symbol or CUSIP number;

                    *    Type of security (stock, bond, note, etc.);

                    *    Number of shares;


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(4) See Appendix 2 for an explanation of beneficial ownership.

(5)  If you are the Chief Investment Officer of an INVESTMENT ADVISER, you must
     receive your preclearance from the General Counsel or his or her designee.


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                    *    Maximum expected dollar amount of proposed transaction;
                         and

                    *    Nature of transaction (purchase or sale).

          3.   Use the "PTRB" routine in the CICS system to view the status of
               your trade requests.

          4.   If you receive PRECLEARANCE for the transaction,(6) you
               have five (5) business days to execute your transaction. If you
               do not execute your transaction within five (5) business days,
               you must repeat the preclearance procedure prior to undertaking
               the transaction.

               American Century reserves the right to restrict the purchase and
               sale by Portfolio, Investment, and Access Persons of any security
               at any time. Such restrictions are imposed through the use of a
               Restricted List that will cause the Code of Ethics system to deny
               the approval of preclearance to transact in the security.
               Securities may be restricted for a variety of reasons including,
               without limitation, the possession of material nonpublic
               information by American Century or its employees.

     C.   ADDITIONAL TRADING RESTRICTIONS [INVESTMENT AND PORTFOLIO PERSONS]

          The following additional trading restrictions apply if you are an
          Investment or Portfolio Person:

          1.   Initial Public Offerings.

               You may not acquire SECURITIES issued in an INITIAL PUBLIC
               OFFERING.

          2.   Private Placements.

               Before you acquire any SECURITIES in a PRIVATE PLACEMENT, you
               must obtain approval from the Chief Investment Officer. Request
               for preclearance can be submitted by entering your request in
               PTRA and accessing the Private Placement screen (PF9 after your
               initials are entered) or by sending your request to "LG-PERSONAL
               SECURITY TRADES." You may not participate in any consideration of
               an investment in securities of the private placement issuer for
               any client portfolios while your preclearance is pending or
               during any period that you own, or are a BENEFICIAL OWNER of, the
               privately-placed security.

          3.   Short-Term Trading Profits.

               You may not profit from any purchase and sale, or sale and
               purchase, of the same (or equivalent) securities other than
               CODE-EXEMPT SECURITIES within sixty (60) calendar days.

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(6) See Appendix 4 for a description of the preclearance process.

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     D.   SEVEN-DAY BLACKOUT PERIOD [PORTFOLIO PERSONS]

          If you are a Portfolio Person, you may not purchase or sell a SECURITY
          other than a CODE-EXEMPT SECURITY within seven (7) calendar days
          before and after it has been traded as a part of a client portfolio
          that you manage.

     E.   TRADING ON INSIDE INFORMATION [ALL EMPLOYEES]

          As you are aware, federal law prohibits you from trading based on
          material nonpublic information received from any source or
          communicating this information to others. This includes any
          confidential information that may be obtained by American Century
          employees regarding the advisability of purchasing or selling specific
          SECURITIES on behalf of clients. You are expected to abide by the
          highest ethical and legal standards in conducting your personal
          investment activities. For more information regarding what to do when
          you believe you are in possession of material nonpublic information,
          please consult American Century's INSIDER TRADING POLICY.

     F.   TRADING IN AMERICAN CENTURY MUTUAL FUNDS [ALL EMPLOYEES]

          Excessive, short-term trading of American Century client portfolios
          and other abusive trading practices (such as time zone arbitrage) may
          disrupt portfolio management strategies and harm fund performance.
          These practices can cause funds to maintain higher-than-normal cash
          balances and incur increased trading costs. Short-term and other
          abusive trading strategies can also cause unjust dilution of
          shareholder value if such trading is based on information not
          accurately reflected in the price of the fund.

          You may not engage in short-term trading or other abusive trading
          strategies with respect to any American Century client portfolio. For
          purposes of this Code, American Century client portfolios include any
          mutual fund, variable annuity, institutional, or other account advised
          or subadvised by American Century.(7)

          FIVE-DAY HOLDING PERIOD. You will be deemed to have engaged in
          short-term trading if you have purchased shares or otherwise invested
          in a variable-priced (i.e., non-money market) American Century client
          portfolio (whether directly or through a brokerage, retirement plan,
          or other intermediary) and redeem shares or otherwise withdraw assets
          from that portfolio within five (5) business days. In other words, if
          you make an investment in an American Century fund, you may not redeem
          shares from that fund before the completion of the fifth (5th)
          business day following the purchase date.

          LIMITED TRADING WITHIN 30 DAYS. We realize that abusive trading is not
          limited to a 5-day window. As a result, persons subject to this Code
          of Ethics are also limited to having not more than two (2) instances
          during any 12-month period of purchasing shares or otherwise investing
          in any variable-priced American Century client portfolio (whether
          directly or through a brokerage, retirement plan, or other
          intermediary) and redeeming shares or otherwise withdrawing assets
          from that portfolio within 30 calendar days. In other words, persons
          subject to this Code are limited during any 12-month period to not
          more than two (2) round trips (i.e., a purchase and sale) in all
          American Century funds within 30 calendar days.

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(7)  See Schedule A for a list of Fund Clients. See Schedule B for a list of
     SUBADVISED FUNDS.


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          One round trip within 30 calendar days will subject that trade to
          scrutiny to determine whether the trade was abusive. Two round trips
          will receive additional scrutiny. Three or more round trips will be
          considered a violation.

          TRANSACTIONS SUBJECT TO LIMITATIONS. These trading restrictions are
          applicable to any account for which you have the authority to direct
          trades or of which you are a BENEFICIAL OWNER. Automatic investments
          such as AMIs, dividend reinvestments, employer plan contributions, and
          payroll deductions are not considered transactions for purposes of
          commencing the 5- and 30-day holding requirements. Check writing
          redemptions in a variable-priced fund will not be considered
          redemptions for purposes of these requirements.

          INFORMATION TO BE PROVIDED. To aid in the monitoring of these
          restrictions, you are required to provide certain information
          regarding mutual fund accounts beneficially owned by you. See the
          Reporting Requirements for your applicable Code of Ethics
          classification.

V.   REPORTING REQUIREMENTS.

     You are required to file complete, accurate, and timely reports of all
     required information under this Code. All such information is subject to
     review for indications of abusive trading, misappropriation of information,
     or failure to adhere to the requirements of the Code of Ethics.

     A.   REPORTING REQUIREMENTS APPLICABLE TO ALL EMPLOYEES

          1.   Code Acknowledgement

               Upon employment, any amendment of the Code, and not less than
               annually thereafter, you will be required to acknowledge that you
               have received, read, and will comply with this Code. Non-Access
               persons will receive an e-mail requesting such information.
               Access, Investment, and Portfolio Persons are required to provide
               this information and acknowledgement as a part of their Initial
               and Annual Holdings Reports and will receive an e-mail requesting
               such information upon any amendment of the Code.

          2.   Reporting of Mutual Fund Accounts

               a.   Direct Accounts/American Century Retirement Plans

                    No transaction reporting is necessary for mutual fund
                    accounts held directly through American Century under your
                    social security number or for American Century retirement
                    plans. Trading in such accounts will be monitored based on
                    information contained on our transfer agency system.
                    Investment and Portfolio Persons must include holdings in
                    these accounts on their Initial and Annual Holdings Reports.


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               b.   Beneficially Owned Direct Accounts

                    You must report the following information for mutual fund
                    accounts in which you have a BENEFICIAL OWNERSHIP interest
                    held directly through American Century under a taxpayer
                    identification or social security number other than your own
                    (so-called "BENEFICIALLY OWNED DIRECT ACCOUNTS"):

                    *    Account number; and

                    *    Name(s) of record owner(s) of the account.

                    Transaction reporting will not be required on such accounts
                    as trading will be monitored based on information contained
                    on our transfer agency system.

               c.   Certain Third-Party Accounts

                    Certain third-party accounts in which you have a BENEFICIAL
                    OWNERSHIP interest in REPORTABLE MUTUAL FUNDS must be
                    reported. These "REPORTABLE THIRD-PARTY ACCOUNTS" include
                    any (i) accounts in which you own or BENEFICIALLY OWN any
                    SUBADVISED FUND (see Schedule B of this Code for a list of
                    SUBADVISED FUNDS); and (ii) non-American Century retirement
                    plan, unit investment trust, variable annuity, or similar
                    accounts in which you own or BENEFICIALLY OWN REPORTABLE
                    MUTUAL FUNDS. The following information must be reported for
                    such accounts:

                    *    Name of the financial institution where held;

                    *    Account number; and

                    *    Name(s) of the record owner(s) of the account.

                    In addition, you must provide either account statements or
                    confirmations of trading activity in such REPORTABLE
                    THIRD-PARTY ACCOUNTS to the Code of Ethics Manager within 30
                    calendar days of the end of each calendar quarter. Such
                    statements or confirmations must include all trading
                    activity in such accounts during the preceding calendar
                    quarter.

          3.   Duplicate Confirmations

               You are required to instruct your broker-dealer to send duplicate
               confirmations of all transactions in reportable brokerage
               accounts to:

               Attention: Compliance
               P.O. Box 410141
               Kansas City, MO 64141-0141

               "REPORTABLE BROKERAGE ACCOUNTS" include both brokerage accounts
               maintained by you and brokerage accounts maintained by a person
               whose trades you must report because you are a BENEFICIAL OWNER.

     B.   ADDITIONAL REPORTING REQUIREMENTS FOR ACCESS, INVESTMENT, AND
          PORTFOLIO PERSONS

          1.   Initial Holdings Report

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               Within ten (10) calendar days of becoming an Access, Investment,
               or Portfolio Person, you must submit an Initial Holdings Report.
               The information submitted must be current as of a date no more
               than 45 calendar days before the report is filed and include the
               following:

               *    A list of all SECURITIES, other than certain CODE-EXEMPT
                    SECURITIES(8), that you own or in which you have a BENEFICIAL
                    OWNERSHIP interest. This listing must include the name,
                    number of shares, and principal amount of each covered
                    security.

               *    Investment and Portfolio Persons must also provide a list of
                    all REPORTABLE MUTUAL FUND holdings owned or in which they
                    have a BENEFICIAL OWNERSHIP interest. This list must include
                    investments held directly through American Century,
                    investments in any SUBADVISED FUND, holdings in a REPORTABLE
                    BROKERAGE ACCOUNT, and holdings in non-American Century
                    retirement plans, unit investment trusts, variable annuity,
                    or similar accounts.

          2.   Quarterly Transactions Report

               Within thirty (30) calendar days of the end of each calendar
               quarter, all Portfolio, Investment and Access persons must submit
               a Quarterly Transactions Report. These persons will be reminded
               by electronic mail of the dates and requirements for filing the
               report. This reminder will contain a link to a database that will
               generate a report of the transactions for which we have received
               duplicate trade confirmations during the quarter. It is your
               responsibility to review the completeness and accuracy of this
               report, provide any necessary changes, and certify its contents
               when submitted.

               a.   The Quarterly Transactions Report must contain the following
                    information about each personal securities transaction
                    undertaken during the quarter other than those in certain
                    CODE-EXEMPT SECURITIES(9):

                    *    The date of the transaction, the security description
                         and number of shares or the principal amount of each
                         SECURITY involved;

                    *    The nature of the transaction, that is, purchase, sale,
                         or any other type of acquisition or disposition;

                    *    The transaction price; and

                    *    The name of the bank, broker, or dealer through whom
                         the transaction was executed.

                    In addition, information regarding your reportable brokerage
                    and other accounts should be verified at this time.

-----------------------------
(8)  See Appendix 3 for a listing of CODE-EXEMPT SECURITIES that must be
     reported.

(9)  See Appendix 3 for a listing of CODE-EXEMPT SECURITIES that must be
     reported.


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               b.   Investment and Portfolio Persons are also required to report
                    transactions in REPORTABLE MUTUAL FUNDS. The Quarterly
                    Transactions Report for such persons must contain the
                    following information about each transaction during the
                    quarter:

                    *    The date of the transaction, the fund description and
                         number of shares or units of each TRADE involved;

                    *    The nature of the transaction, that is, purchase, sale,
                         or any other type of acquisition or disposition;

                    *    The transaction price; and

                    *    The name of the bank, broker, or dealer, retirement
                         plan or unit investment trust through whom the
                         transaction was executed.

               c.   Investment and Portfolio Persons do not need to include
                    certain REPORTABLE MUTUAL FUND transactions on their
                    Quarterly Transaction Report where the information relating
                    to such transactions is maintained by American Century, has
                    been concurrently provided, or such transactions are
                    pursuant to an AUTOMATIC INVESTMENT PLAN. Transactions that
                    do not need to be reported include:

                    *    Reinvested dividends;

                    *    Transactions in your American Century retirement plan
                         accounts;

                    *    Transactions in mutual fund accounts held directly
                         through American Century under your social security
                         number;

                    *    Transactions in BENEFICIALLY OWNED DIRECT ACCOUNTS if
                         such account has been previously reported under this
                         Code; and

                    *    Transactions in REPORTABLE THIRD-PARTY ACCOUNTS to the
                         extent that account statements or confirmations
                         containing such transactions have been received by the
                         Code of Ethics Manager within 30 days of the end of the
                         calendar quarter in which such transactions took place.

                    Transactions in REPORTABLE BROKERAGE ACCOUNTS must be
                    included on the Quarterly Transaction Report.

          3.   Annual Holdings Report

               Each year all Portfolio, Investment, and Access Persons must
               submit an Annual Holdings Report and verify their brokerage
               accounts and mutual fund account numbers reported under this
               Code. The Annual Holdings Report must be submitted within 45
               calendar days after December 31st of each year and the
               information submitted must be current as of a date no more than
               45 calendar days before the report is filed. These persons will
               be reminded by electronic mail of the dates and requirements for
               filing the report. The information submitted must be current as
               of a date not more than 45 calendar days before the report is
               filed and include the following:


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               *    A list of all SECURITIES, other than certain CODE-EXEMPT
                    SECURITIES(10), that you own or in which you have a
                    BENEFICIAL OWNERSHIP interest. This listing must include the
                    name, number of shares, and principal amount of each covered
                    security.

               *    Investment and Portfolio Persons must also provide a list of
                    all REPORTABLE MUTUAL FUND holdings owned or in which they
                    have a BENEFICIAL OWNERSHIP interest. This list must include
                    investments held directly through American Century,
                    investments in any SUBADVISED FUND, holdings in a REPORTABLE
                    BROKERAGE ACCOUNT, and holdings in non-American Century
                    retirement plans, unit investment trusts, variable annuity,
                    or similar accounts.

VI.  CAN THERE BE ANY EXCEPTIONS TO THE RESTRICTIONS?

     YES. The General Counsel or his or her designee may grant limited
     exemptions to specific provisions of the Code on a case-by-case basis.

     A.   HOW TO REQUEST AN EXEMPTION

          E-mail a written request to "LG-PERSONAL SECURITY TRADES" (or
          "LG-PERSONAL_SECURITY_TRADES@AMERICANCENTURY.COM" if sending from
          outside American Century's Lotus Notes system) detailing your
          situation.

     B.   FACTORS CONSIDERED

          In considering your request, the General Counsel or his or her
          designee will grant your exemption request if he or she is satisfied
          that:

          *    Your request addresses an undue personal hardship imposed on you
               by the Code of Ethics;

          *    Your situation is not contemplated by the Code of Ethics; and

          *    Your exemption, if granted, would be consistent with the
               achievement of the objectives of the Code of Ethics.

     C.   EXEMPTION REPORTING

          All exemptions must be reported to the Boards of Directors of our Fund
          Clients at the next regular meeting following the initial grant of the
          exemption. Subsequent grants of an exemption of a type previously
          reported to the Boards may be effected without reporting. The Boards
          of Directors may choose to delegate the task of receiving and
          reviewing reports to a committee comprised of Independent Directors.

-----------------------------
(10) See Appendix 3 for a listing of code-exempt securities that must be
     reported.


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     D.   THIRTY-DAY DENIAL EXEMPTION ON SALES

          An exemption may be requested when a request to sell a security has
          been denied once a week over a 30-day timeframe. The covered person
          must be able to verify that they have periodically entered a request
          to sell a security in PTRA at least four times throughout the 30-day
          period. A written request must be e-mailed to "LG-PERSONAL SECURITY
          TRADES" to request the exemption. The General Counsel or his or her
          designee will review the request and determine if the exemption is
          warranted. If approval is granted, compliance will designate a short
          trading window during which the sale can take place.

     E.   NON-VOLITIONAL TRANSACTION EXEMPTION

          Certain non-volitional purchase and sale transactions shall be exempt
          from the preclearance requirements of the Code. These transactions
          shall include stock splits, stock dividends, exchanges and
          conversions, mandatory tenders, pro rata distributions to all holders
          of a class of securities, gifts, inheritances, margin/maintenance
          calls (where the securities to be sold are not directed by the covered
          person), dividend reinvestment plans, and employer sponsored payroll
          deduction plans. These purchase and sale transactions, however, shall
          not be exempt from the Quarterly Transaction Report and Annual
          Holdings Report provisions of the Code.

     F.   BLIND TRUST EXEMPTION

          An exemption from the preclearance and reporting requirements of the
          Code may be requested for SECURITIES that are held in a blind or
          quasi-blind trust arrangement. For the exemption to be available, you
          or a MEMBER OF YOUR IMMEDIATE FAMILY must not have authority to advise
          or direct SECURITIES transactions of the trust. The request will only
          be granted once the covered person and the trust's investment adviser
          certify that the covered person or MEMBERS OF THEIR IMMEDIATE FAMILY
          will not advise or direct transactions. American Century must receive
          statements at least quarterly for transactions within the trust.

VII. CONFIDENTIAL INFORMATION.

     All information about Clients' SECURITIES transactions and portfolio
     holdings is confidential. You must not disclose, except as required by the
     duties of your employment, actual or contemplated SECURITIES transactions,
     portfolio holdings, portfolio characteristics or other nonpublic
     information about Clients, or the contents of any written or oral
     communication, study, report or opinion concerning any SECURITY. This does
     not apply to information which has already been publicly disclosed.

VIII. CONFLICTS OF INTEREST.

     You must receive prior written approval from the General Counsel or his or
     her designee, as appropriate, to do any of the following:

     *    Negotiate or enter into any agreement on a Client's behalf with any
          business concern doing or seeking to do business with the Client if
          you, or a person related to you, has a substantial interest in the
          business concern;

     *    Enter into an agreement, negotiate or otherwise do business on the
          Client's behalf with a personal friend or a person related to you; or

     *    Serve on the board of directors of, or act as consultant to, any
          publicly traded corporation.

                                                                        Page 12


AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
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IX.  WHAT HAPPENS IF YOU VIOLATE THE RULES IN THE CODE OF ETHICS?

     If you violate the rules of the Code of Ethics, you may be subject to
     serious penalties. Violations of the Code and proposed sanctions are
     documented by the Code of Ethics Manager and submitted to the Code of
     Ethics Review Committee. The Committee consists of representatives of each
     INVESTMENT ADVISER and the Compliance and Legal Departments of American
     Century. The Committee is responsible for determining the materiality of a
     Code violation and appropriate sanctions.

     A.   MATERIALITY OF VIOLATION

          In determining the materiality of a violation, the Committee
          considers:

          *    Evidence of violation of law;

          *    Indicia of fraud, neglect, or indifference to Code provisions;

          *    Frequency of violations;

          *    Monetary value of the violation in question; and

          *    Level of influence of the violator.

     B.   PENALTY FACTORS

          In assessing the appropriate penalties, the Committee will consider
          the foregoing in addition to any other factors they deem applicable,
          such as:

          *    Extent of harm to client interests;

          *    Extent of unjust enrichment;

          *    Tenure and prior record of the violator;

          *    The degree to which there is a personal benefit from unique
               knowledge obtained through employment with American Century;

          *    The level of accurate, honest and timely cooperation from the
               covered person; and

          *    Any mitigating circumstances that may exist.

     C.   THE PENALTIES WHICH MAY BE IMPOSED INCLUDE:

          1.   First non-material violation

               a.   Warning (notice sent to manager); and

               b.   Attendance at Code of Ethics training session.

          2.   Second non-material violation within 12 months

               a.   Notice sent to manager; and

               b.   Suspension of trading privileges for up to 90 days.

          3.   Penalties for material or more frequent non-material violations
               will be determined based on the circumstances. These penalties
               could include, but are not limited to

               a.   Suspension of trading privileges;

               b.   Fine; and/or


                                                                        Page 13

AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
-------------------------------------------------------------------------------


               c.   Suspension or termination of employment.

          In addition, you may be required to surrender to American Century any
          profit realized from any transaction(s) in violation of this Code of
          Ethics.

X.   AMERICAN CENTURY'S QUARTERLY REPORT TO FUND DIRECTORS.

          American Century will prepare a quarterly report to the Board of
          Directors of each Fund Client of any material violation of this Code
          of Ethics.





AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
-------------------------------------------------------------------------------

APPENDIX 1:  DEFINITIONS

1.   "AUTOMATIC INVESTMENT PLAN"

     "Automatic investment plan" means a program in which regular periodic
     purchases or withdrawals are made automatically in or from investment
     accounts in accordance with a predetermined schedule and allocation. An
     automatic investment plan includes a dividend reinvestment plan.

2.   "BENEFICIAL OWNERSHIP" OR "BENEFICIALLY OWNED"

     See "Appendix 2: What is Beneficial Ownership?".

3.   "CODE-EXEMPT SECURITY"

     A "code-exempt security" is a security in which you may invest without
     preclearing the transaction with American Century. The list of code-exempt
     securities appears in Appendix 3.

4.   "FEDERAL SECURITIES LAW"

     Federal securities law means the Securities Act of 1933, the Securities Act
     of 1934, the Sarbannes-Oxley Act of 2002, the Investment Company Act of
     1940, the Investment Advisers Act of 1940, Title V of the
     Gramm-Leach-Bliley Act, any rules adopted by the Commission under any of
     these statutes, the Bank Secrecy Act as it applies to funds and investment
     advisers, and any rules adopted thereunder by the Commission or the
     Department of Treasury

5.   "INITIAL PUBLIC OFFERING"

     "Initial public offering" means an offering of securities for which a
     registration statement has not previously been filed with the SEC and for
     which there is no active public market in the shares.

6.   "INVESTMENT ADVISER"

     "Investment adviser" includes each investment adviser listed on Schedule A
     attached hereto.

7.   "MEMBER OF YOUR IMMEDIATE FAMILY"

     A "member of your immediate family" means any of the following

     *    Your spouse or domestic partner;

     *    Your minor children; or

     *    A relative who shares your home


                                                            Appendix 1 - Page 1


AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
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     For the purpose of determining whether any of the foregoing relationships
     exist, a legally adopted child of a person is considered a child of such
     person.

8.   "PRIVATE PLACEMENT"

     "Private placement" means an offering of securities in which the issuer
     relies on an exemption from the registration provisions of the federal
     securities laws, and usually involves a limited number of sophisticated
     investors and a restriction on resale of the securities.

9.   "REPORTABLE MUTUAL FUND"

     A "reportable mutual fund" includes any mutual fund issued by a Fund Client
     (as listed on Schedule A) and any SUBADVISED FUNDS (as listed on Schedule
     B).

10.  "SECURITY"

     A "security" includes a great number of different investment vehicles.
     However, for purposes of this Code of Ethics, "security" includes any of
     the following:

     *    Note,

     *    Stock,

     *    Treasury stock,

     *    Bond,

     *    Debenture,

     *    Exchange traded funds (ETFs) or similar securities,

     *    Shares of open-end mutual funds,

     *    Shares of closed-end mutual funds,

     *    Evidence of indebtedness,

     *    Certificate of interest or participation in any profit-sharing
          agreement,

     *    Collateral-trust certificate,

     *    Preorganization certificate or subscription,

     *    Transferable share,

     *    Investment contract,

     *    Voting-trust certificate,

     *    Certificate of deposit for a security,

     *    Fractional undivided interest in oil, gas or other mineral rights,

     *    Any put, call, straddle, option, future, or privilege on any security
          or other financial instrument (including a certificate of deposit) or
          on any group or index of securities (including any interest therein or
          based on the value thereof),

     *    Any put, call, straddle, option, future, or privilege entered into on
          a national securities exchange relating to foreign currency,


                                                            Appendix 1 - Page 2


AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
-------------------------------------------------------------------------------


     *    In general, any interest or instrument commonly known as a "security,"
          or

     *    Any certificate of interest or participation in, temporary or interim
          certificate for, receipt for, guarantee of, future on or warrant or
          right to subscribe to or purchase, any of the foregoing.

11.  "SUBADVISED FUND"

     A "subadvised fund" means any mutual fund or portfolio listed on Schedule
     B.

12.  "SUPERVISED PERSON"

     A "supervised person" means any partner, officer, director (or other person
     occupying a similar status or performing similar functions), or employee of
     an INVESTMENT ADVISER, or other person who provides investment advice on
     behalf of an INVESTMENT ADVISER and is subject to the supervision and
     control of the INVESTMENT ADVISER.


                                                            Appendix 1 - Page 3





AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
-------------------------------------------------------------------------------

APPENDIX 2:  WHAT IS "BENEFICIAL OWNERSHIP"?

A "beneficial owner" of a security is any person who, directly or indirectly,
through any contract, arrangement, understanding, relationship, or otherwise,
has or shares in the opportunity, directly or indirectly, to profit or share in
any profit derived from a purchase or sale of the security.

1.   ARE SECURITIES HELD BY FAMILY MEMBERS OR DOMESTIC PARTNERS "BENEFICIALLY
     OWNED" BY ME?

     PROBABLY. As a general rule, you are regarded as the beneficial owner of
     SECURITIES held in the name of

     *    A MEMBER OF YOUR IMMEDIATE FAMILY OR

     *    Any other person IF:

          *    You obtain from such SECURITIES benefits substantially similar to
               those of ownership. For example, if you receive or benefit from
               some of the income from the SECURITIES held by your spouse, you
               are the beneficial owner; OR

          *    You can obtain title to the SECURITIES now or in the future.

2.   ARE SECURITIES HELD BY A COMPANY I OWN AN INTEREST IN ALSO "BENEFICIALLY
     OWNED" BY ME?

     PROBABLY NOT. Owning the SECURITIES of a company does not mean you
     "beneficially own" the SECURITIES that the company itself owns. HOWEVER,
     you will be deemed to "beneficially own" the SECURITIES owned by the
     company if:

     *    You directly or beneficially own a controlling interest in or
          otherwise control the company; OR

     *    The company is merely a medium through which you, MEMBERS OF YOUR
          IMMEDIATE FAMILY, or others in a small group invest or trade in
          SECURITIES and the company has no other substantial business.

3.   ARE SECURITIES HELD IN TRUST "BENEFICIALLY OWNED" BY ME?

     MAYBE. You are deemed to "beneficially own" SECURITIES held in trust if any
     of the following is true:

     *    You or a MEMBER OF YOUR IMMEDIATE FAMILY are a trustee or have a
          vested interest in the income or corpus of the trust OR

     *    You or a MEMBER OF YOUR IMMEDIATE FAMILY are a settlor or grantor of
          the trust and have the power to revoke the trust without obtaining the
          consent of all the beneficiaries.

     A blind trust exemption from the preclearance and reporting requirements of
     the Code may be requested if you or MEMBERS OR YOUR IMMEDIATE FAMILY do not
     have authority to advise or direct SECURITIES transactions of the trust.


                                                            Appendix 2 - Page 1



AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
-------------------------------------------------------------------------------

4.   ARE SECURITIES IN PENSION OR RETIREMENT PLANS "BENEFICIALLY OWNED" BY ME?

     MAYBE. Beneficial ownership does not include indirect interest by any
     person in portfolio SECURITIES held by a pension or retirement plan holding
     SECURITIES of an issuer whose employees generally are the beneficiaries of
     the plan.

     However, your participation in a pension or retirement plan is considered
     beneficial ownership of the portfolio SECURITIES if you can withdraw and
     trade the SECURITIES without withdrawing from the plan or you can direct
     the trading of the SECURITIES within the plan (IRAs, 401ks, etc.).

5.   EXAMPLES OF BENEFICIAL OWNERSHIP

     a.   Securities Held by Family Members or Domestic Partners

     EXAMPLE 1: Tom and Mary are married. Although Mary has an independent
     source of income from a family inheritance and segregates her funds from
     those of her husband, Mary contributes to the maintenance of the family
     home. Tom and Mary have engaged in joint estate planning and have the same
     financial adviser. Since Tom and Mary's resources are clearly significantly
     directed towards their common property, they shall be deemed to be the
     beneficial owners of each other's SECURITIES.

     EXAMPLE 2: Mike's adult son David lives in Mike's home. David is
     self-supporting and contributes to household expenses. Mike is a beneficial
     owner of David's SECURITIES.

     EXAMPLE 3: Joe's mother Margaret lives alone and is financially
     independent. Joe has power of attorney over his mother's estate, pays all
     her bills and manages her investment affairs. Joe borrows freely from
     Margaret without being required to pay back funds with interest, if at all.
     Joe takes out personal loans from Margaret's bank in Margaret's name, the
     interest from such loans being paid from Margaret's account. Joe is a
     significant heir of Margaret's estate. Joe is a beneficial owner of
     Margaret's estate.

     EXAMPLE 4: Bob and Nancy are engaged. The house they share is still in
     Nancy's name only. They have separate checking accounts with an informal
     understanding that both individuals contribute to the mortgage payments and
     other common expenses. Nancy is the beneficial owner of Bob's SECURITIES.

     b.   Securities Held by a Company

     EXAMPLE 5: ABC Company is a holding company with five shareholders owning
     equal shares in the company. Although ABC Company has no business of its
     own, it has several wholly-owned subsidiaries that invest in SECURITIES.
     Stan is a shareholder of ABC Company. Stan has a beneficial interest in the
     SECURITIES owned by ABC Company's subsidiaries.

     EXAMPLE 6: XYZ Company is a large manufacturing company with many
     shareholders. Stan is a shareholder of XYZ Company. As a part of its cash
     management function, XYZ Company invests in SECURITIES. Neither Stan nor
     any MEMBERS OF HIS IMMEDIATE FAMILY are employed by XYZ Company. Stan does
     not beneficially own the SECURITIES held by XYZ Company.


                                                            Appendix 2 - Page 2



AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
-------------------------------------------------------------------------------


     c.   Securities Held in Trust

     EXAMPLE 7: John is trustee of a trust created for his two minor children.
     When both of John's children reach 21, each shall receive an equal share of
     the corpus of the trust. John is a beneficial owner of any SECURITIES owned
     by the trust.

     EXAMPLE 8: Jane placed SECURITIES held by her in a trust for the benefit of
     her church. Jane can revoke the trust during her lifetime. Jane is a
     beneficial owner of any SECURITIES owned by the trust.

     EXAMPLE 9: Jim is trustee of an irrevocable trust for his 21 year-old
     daughter (who does not share his home). The daughter is entitled to the
     income of the trust until she is 25 years old, and is then entitled to the
     corpus. If the daughter dies before reaching 25, Jim is entitled to the
     corpus. Jim is a beneficial owner of any SECURITIES owned by the trust.

     EXAMPLE 10: Joan's father (who does not share her home) placed SECURITIES
     in an irrevocable trust for Joan's minor children. Neither Joan nor any
     MEMBER OF HER IMMEDIATE FAMILY is the trustee of the trust. Joan is a
     beneficial owner of the SECURITIES owned by the trust. She may, however, be
     eligible for the blind trust exemption to the preclearance and reporting of
     the trust SECURITIES.


                                                            Appendix 2 - Page 3






AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
-------------------------------------------------------------------------------

APPENDIX 3:  CODE-EXEMPT SECURITIES

Because they do not pose a likelihood for abuse, some securities, defined as
code-exempt securities, are exempt from the Code's preclearance requirements.
However, confirmations from your service providers are required in all cases
(except non- REPORTABLE MUTUAL FUNDS) and some code-exempt securities must be
disclosed on your Quarterly Transactions, Initial and Annual Holdings Reports.

1.   CODE-EXEMPT SECURITIES NOT SUBJECT TO DISCLOSURE ON YOUR QUARTERLY
     TRANSACTIONS, INITIAL AND ANNUAL HOLDINGS REPORTS:

     *    Open-end mutual funds that are not considered REPORTABLE MUTUAL FUND;,

     *    REPORTABLE MUTUAL FUNDS (Access Persons only);

     *    REPORTABLE MUTUAL FUND shares purchased through an AUTOMATIC
          INVESTMENT PLAN (including reinvested dividends);

     *    Money market mutual funds;

     *    Bank Certificates of Deposit;

     *    U.S. government securities (Treasury notes, etc.);,

     *    Commercial paper;

     *    Bankers acceptances;

     *    High quality short-term debt instruments, including repurchase
          agreements. A "high quality short-term debt instrument" means any
          instrument that has a maturity at issuance of less than 366 days and
          that is rated in one of the two highest rating categories by a
          nationally recognized rating organization.

2.   CODE-EXEMPT SECURITIES SUBJECT TO DISCLOSURE ON YOUR QUARTERLY
     TRANSACTIONS, INITIAL AND ANNUAL HOLDINGS REPORTS:

     *    REPORTABLE MUTUAL FUND shares purchased other than through an
          AUTOMATIC INVESTMENT PLAN (Investment and Portfolio Persons only)

     *    Securities which are acquired through an employer-sponsored automatic
          payroll deduction plan (only the acquisition of the security is
          exempt, NOT the sale)

     *    Securities (other than open-end mutual funds) purchased through
          dividend reinvestment programs (only the re-investment of dividends in
          the security is exempt, NOT the sale or other purchases)

     *    Commodity futures contracts for tangible goods (corn, soybeans, wheat,
          etc.) Futures contracts for financial instruments are NOT Code-exempt.

     *    Futures contracts on the following:

          *    Standard & Poor's 500 Index; or

          *    Standard & Poor's 100 Index.


                                                            Appendix 3 - Page 1



AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
-------------------------------------------------------------------------------


We may modify this list of securities at any time, please send an e-mail to
"LG-PERSONAL SECURITY TRADES" to request the most current list.


                                                            Appendix 3 - Page 2




AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
-------------------------------------------------------------------------------

APPENDIX 4: HOW THE PRECLEARANCE PROCESS WORKS

                                                            Appendix 4 - Page 1





AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
-------------------------------------------------------------------------------
After your request is entered into our mainframe system, it is then subjected to
the following tests.

STEP 1: RESTRICTED SECURITY LIST

*    Is the security on the Restricted Security list?

IF "YES", the system will send a message to you to DENY the personal trade
request.

IF "NO", then your request is subject to Step 2.

STEP 2: DE MINIMIS TRANSACTION TEST (THIS TEST DOES NOT APPLY TO THE TRADE
     REQUESTS OF PORTFOLIO AND INVESTMENT PERSONS.)

*    Is the security issuer's market capitalization greater than $1 billion?

*    Will your proposed transaction, together with your other transactions in
     the security for the current calendar quarter, be less than $10,000?

*    Does the security trade on a national securities exchange or market, such
     as the New York Stock Exchange (NYSE) or National Association of Securities
     Dealers Automated Quotation System (NASDAQ)?

IF THE ANSWER TO ALL OF THESE QUESTIONS IS "YES", the system will generate a
message and send it to you approving your proposed transaction.

IF THE ANSWER TO ANY OF THESE QUESTIONS IS "NO", then your request is subject to
Step 3.

STEP 3: OPEN ORDER TEST

*    Is there an open order for that security for any Client?

IF "YES", the system will send a message to you to DENY the personal trade
request.

IF "NO", then your request is subject to Step 4.

STEP 4: FOLLOW LIST TEST

*    Does any account or Fund own the security?

*    Does the security appear on the computerized list of stocks American
     Century is considering to purchase for a Client?

IF THE ANSWER TO BOTH OF THESE QUESTIONS IS "NO", the system will send a message
to you to APPROVE your proposed transaction.

IF THE ANSWER TO EITHER OF THESE QUESTIONS IS "YES", then your request is
subject to Step 5.

STEP 5: PRESENT INTENTIONS TEST

The system sends a message to our equity trading desk in Kansas City which
identifies the security described in your preclearance request. A trading desk
representative will review the request for recent activity in the security. The
trading desk representative may deny the request based on recent trading
activity. If not denied, the trading desk will contact a representative from
each of the portfolio management teams that have the security on their follow
list or own the security. The portfolio teams will be asked if they intend to
buy or sell the security within the next five (5) business days.


                                                            Appendix 4 - Page 2


AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
-------------------------------------------------------------------------------
IF ALL OF THE PORTFOLIO MANAGEMENT TEAMS RESPOND "NO", your request will be
APPROVED.

If ANY OF THE PORTFOLIO MANAGEMENT TEAMS RESPOND "YES", your request will be
DENIED.

STEP 6: CHIEF INVESTMENT OFFICER REQUESTS

The General Counsel or his/her designee must approve any preclearance request by
ACIM's Chief Investment Officer before an APPROVAL message is generated.

THE PRECLEARANCE PROCESS CAN BE CHANGED AT ANY TIME TO ENSURE THAT THE GOALS OF
AMERICAN CENTURY'S CODE OF ETHICS ARE ADVANCED.


                                                            Appendix 4 - Page 3





AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
-------------------------------------------------------------------------------

                                   SCHEDULE A

The Code of Ethics to which this Schedule is attached was most recently approved
by the Board of Directors/Trustees of the following Companies as of the dates
indicated:

-------------------------------------------------------------------------------
                                                                Most Recent
       Investment Advisers                                     Approval Date
-------------------------------------------------------------------------------
       American Century Investment Management, Inc.           January 1, 2005
       American Century Global Investment Management, Inc.    January 1, 2005
-------------------------------------------------------------------------------


-------------------------------------------------------------------------------
                                                                Most Recent
       Principal Underwriter                                   Approval Date
-------------------------------------------------------------------------------
       American Century Investment Services, Inc.             January 1, 2005
-------------------------------------------------------------------------------


-------------------------------------------------------------------------------
                                                                Most Recent
       Fund Clients                                            Approval Date
-------------------------------------------------------------------------------
       American Century Asset Allocation Portfolios, Inc.     November 16, 2004
       American Century California Tax-Free and Municipal
         Funds                                                December 9, 2004
       American Century Capital Portfolios, Inc.              November 16, 2004
       American Century Government Income Trust               December 9, 2004
       American Century International Bond Funds              December 9, 2004
       American Century Investment Trust                      December 9, 2004
       American Century Municipal Trust                       December 9, 2004
       American Century Mutual Funds, Inc.                    November 16, 2004
       American Century Quantitative Equity Funds, Inc.       December 9, 2004
       American Century Strategic Asset Allocations, Inc.     November 16, 2004
       American Century Target Maturities Trust               December 9, 2004
       American Century Variable Portfolios, Inc.             November 16, 2004
       American Century Variable Portfolios II, Inc.          December 9, 2004
       American Century World Mutual Funds, Inc.              November 16, 2004
-------------------------------------------------------------------------------




AMERICAN CENTURY INVESTMENTS                                     CODE OF ETHICS
-------------------------------------------------------------------------------

                                   SCHEDULE B

The Code of Ethics to which this Schedule is attached applies to the following
funds which are subadvised by an INVESTMENT ADVISER. This list of affiliated
funds will be updated on a regular basis:

        AEGON/Transamerica American Century International
        AEGON/Transamerica American Century Large Company Value
        AST American Century Income & Growth Portfolio
        AST American Century Strategic Balanced Portfolio
        AXP Discovery Fund
        AXP Partners Aggressive Growth Fund
        AXP Partners International Aggressive Growth Fund
        AXP Partners Small Cap Core Fund
        GVIT (Gartmore Variable Insurance Trust) Small Company Fund
        ING American Century Select Portfolio
        ING American Century Small Cap Value Portfolio
        Mainstay VP American Century Income & Growth Portfolio
        Manufactures Investment Trust Small Company Trust
        MassMutual Overseas Fund
        Principal Investors Partners LargeCap Growth Fund II
        Principal Partners LargeCap Value Fund II
        Principal Variable Contracts Equity Value Account
        Schwab Capital Trust Laudus International MarketMasters Fund
        Season Series Trust Focus Value Portfolio
        Strategic Partners Balanced Fund
        SunAmerica Focused Large-Cap Growth Portfolio
        Sun-America Focused Multi-Cap Value Portfolio
        TransAmerica IDEX American Century International
        TransAmerica IDEX American Century Large Company Value
        VALIC Company Income & Growth Fund
        VALIC Company International Growth I Fund
        VALIC Company Small Cap Fund
        JPMorgan Fleming Investment Funds - Global ex-US Small Cap Fund
        SEI Trust Company International Growth Commingled Fund A
        Learning Quest 529 Education Savings Program